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{{#Wiki_filter:ATTACHMENT 8NEDC-33576NP, SAFETY ANALYSIS REPORT FORNINE MILE POINT UNIT 2MAXIMUM EXTENDED LOAD LINE LIMIT ANALYSIS PLUS(NON-PROPRIETARY)
Nine Mile Point Nuclear Station, LLCNovember 1, 2013 0HITACHIGE Hitachi Nuclear EnergyNEDO-33576 Revision 0DRF Section 0000-0138-0146 R6October 2013Non-Proprietary Information
-Class I (Public)Safety Analysis ReportforNine Mile Point Unit 2Maximum Extended Load Line Limit Analysis PlusCopyright 2013 GE-Hitachi Nuclear Energy Americas LLCAll Rights Reserved NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)INFORMATION NOTICEThis is a non-proprietary version of the document NEDC-33576P, Revision 0, which has theproprietary information removed.
Portions of the document that have been removed areindicated by an open and closed bracket as shown here [[IMPORTANT NOTICE REGARDING CONTENTS OF THIS REPORTPlease Read Carefully The design, engineering, and other information contained in this document is furnished for thepurposes of supporting the Constellation Energy Nuclear Group (CENG) license amendment request for a Maximum Extended Load Line Limit Analysis Plus at Nine Mile Point Unit 2 inproceedings before the U.S. Nuclear Regulatory Commission.
The only undertakings of GEHwith respect to information in this document are contained in the contracts between GEH and itscustomers or participating utilities, and nothing contained in this document shall be construed aschanging that contract.
The use of this information by anyone for any purpose other than that forwhich it is intended, is not authorized; and with respect to any unauthorized use, GEH makes norepresentation or warranty, and assumes no liability as to the completeness,
: accuracy, orusefulness of the information contained in this document.
ii NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)TABLE OF CONTENTSPageExecutive Sum m ary .....................................................................................................................
ixA cronym s ......................................................................................................................................
xi1.0 Introduction
....................................................................................................................
1-11.1 Report Approach
...........................................................................................................
1-21.2 Operating Conditions and Constraints
...........................................................................
1-71.3 Sum m ary and Conclusions
............................................................................................
1-92.0 Reactor C ore and Fuel Perform ance ...........................................................................
2-12.1 Fuel Design and Operation
............................................................................................
2-12.2 Therm al Lim its A ssessm ent ..........................................................................................
2-32.3 Reactivity Characteristics
..............................................................................................
2-62.4 Stability
..........................................................................................................................
2-82.5 Reactivity Control .......................................................................................................
2-142.6 Additional Limitations and Conditions Related to Reactor Core and FuelPerform ance ............................................................................................................
2-153.0 Reactor C oolant and C onnected System s ....................................................................
3-13.1 N uclear System Pressure Relief and Overpressure Protection
......................................
3-13.2 Reactor Vessel ...............................................................................................................
3-23.3 Reactor Internals
............................................................................................................
3-33.4 Flow -Induced V ibration
..............................................................................................
3-103.5 Piping Evaluation
........................................................................................................
3-133.6 Reactor Recirculation System .....................................................................................
3-203.7 M ain Steam Line Flow Restrictors
..............................................................................
3-223.8 M ain Steam Isolation Valves .......................................................................................
3-233.9 Reactor Core Isolation Cooling ...................................................................................
3-233.10 Residual Heat Rem oval System ..................................................................................
3-253.11 Reactor W ater Cleanup System ...................................................................................
3-264.0 Engineered Safety Features
..........................................................................................
4-14.1 Containm ent System Perform ance ................................................................................
4-14.2 Em ergency Core Cooling System s ................................................................................
4-64.3 Em ergency Core Cooling System Perform ance ..........................................................
4-104.4 M ain Control Room A tm osphere Control System ......................................................
4-174.5 Standby G as Treatm ent System ...................................................................................
4-174.6 M ain Steam Isolation Valve Leakage Control System ................................................
4-184.7 Post-LO CA Com bustible G as Control System ...........................................................
4-185.0 Instrum entation and C ontrol ........................................................................................
5-15.1 N SSS M onitoring and Control ......................................................................................
5-15.2 BO P M onitoring and Control ........................................................................................
5-35.3 Technical Specification Instrum ent Setpoints
...............................................................
5-6iii NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)6.0 Electrical Pow er and A uxiliary System s ......................................................................
6-16.1 A C Pow er ......................................................................................................................
6-I6.2 D C Pow er ......................................................................................................................
6-16.3 Fuel Pool ........................................................................................................................
6-26.4 W ater System s ...............................................................................................................
6-36.5 Standby Liquid Control System ....................................................................................
6-46.6 H eating, Ventilation And A ir Conditioning
..................................................................
6-66.7 Fire Protection
...............................................................................................................
6-66.8 Other System s A ffected .................................................................................................
6-77.0 Pow er C onversion System s ...........................................................................................
7-17.1 Turbine-G enerator
.........................................................................................................
7-17.2 Condenser and Steam Jet A ir Ejectors
..........................................................................
7-17.3 Turbine Steam Bypass ...................................................................................................
7-27.4 Feedw ater and Condensate System s ..............................................................................
7-28.0 R adw aste System s and Radiation Sources ..................................................................
8-18.1 Liquid and Solid W aste M anagem ent ...........................................................................
8-18.2 G aseous W aste M anagem ent .........................................................................................
8-18.3 Radiation Sources in the Reactor Core ..........................................................................
8-38.4 Radiation Sources in Reactor Coolant ...........................................................................
8-38.5 Radiation Levels ............................................................................................................
8-48.6 N orm al O peration O ff-Site D oses .................................................................................
8-69.0 R eactor Safety Perform ance Evaluations
....................................................................
9-19.1 Anticipated Operational O ccurrences
............................................................................
9-19.2 Design Basis Accidents and Events of Radiological Consequence
..............................
9-49.3 Special Events .............................................................................................................
9-1010.0 O ther Evaluations
........................................................................................................
10-110.1 H igh Energy Line Break ..............................................................................................
10-110.2 M oderate Energy Line Break ......................................................................................
10-210.3 Environm ental Q ualification
.......................................................................................
10-310.4 Testing .........................................................................................................................
10-510.5 Individual Plant Exam ination ......................................................................................
10-610.6 Operator Training and Hum an Factors ......................................................................
10-1110.7 Plant Life ...................................................................................................................
10-1210.8 N RC and Industry Com m unications
.........................................................................
10-1510.9 Em ergency and Abnorm al Operating Procedures
.....................................................
10-1511.0 Licensing Evaluations
..................................................................................................
11-111.1 Effect on Technical Specifications
..............................................................................
11-111.2 Environm ental A ssessm ent .........................................................................................
11-111.3 Significant Hazards Consideration A ssessm ent ..........................................................
11-212.0 R eferences
.....................................................................................................................
12-1iv NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Appendix A ............................................................................................................................
A -1Appendix B .............................................................................................................................
B-1A ppendix C .............................................................................................................................
C-1V NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)List of FiguresFigure Title PageFigure 1-1 Power/Flow Operating Map for MELLLA+ ........................................................
1-14Figure 2-1 Power of Peak Bundle versus Cycle Exposure
.....................................................
2-22Figure 2-2 Coolant Flow for Peak Bundle versus Cycle Exposure
........................................
2-23Figure 2-3 Exit Void Fraction for Peak Power Bundle versus Cycle Exposure
.....................
2-24Figure 2-4 Maximum Channel Exit Void Fraction versus Cycle Exposure
...........................
2-25Figure 2-5 Core Average Exit Void Fraction versus Cycle Exposure
....................................
2-26Figure 2-6 Peak LHGR versus Cycle Exposure
.....................................................................
2-27Figure 2-7 Dimensionless Bundle Power at BOC (200 MWd/ST) ........................................
2-28Figure 2-8 Dimensionless Bundle Power at MOC (10,000 MWd/ST) ..................................
2-29Figure 2-9 Dimensionless Bundle Power at EOC (18,577 MWd/ST) ....................................
2-30Figure 2-10 Bundle Operating LHGR (kW/ft) at BOC (200 MWd/ST) ..................................
2-31Figure 2-11 Bundle Operating LHGR (kW/ft) at MOC (10,000 MWd/ST) ............................
2-32Figure 2-12 Bundle Operating LHGR (kW/ft) at EOC (18,577 MWd/ST) .............................
2-33Figure 2-13 Bundle Operating MCPR at BOC (200 MWd/ST) ...............................................
2-34Figure 2-14 Bundle Operating MCPR at MOC (10,000 MWd/ST) .........................................
2-35Figure 2-15 Bundle Operating MCPR at EOC (18,577 MWd/ST) ..........................................
2-36Figure 2-16 Bundle Operating LHGR (kW/ft) at 15,000 MWd/ST (Peak MFLPD Point) ...... 2-37Figure 2-17 Bundle Operating MCPR at 1,500 MWd/ST (Peak MFLCPR Point) ..................
2-38Figure 2-18 Bundle Average Void History for Bundles with Low CPRs ................................
2-39Figure 2-19 Required OPRM Arm ed Region ...........................................................................
2-40Figure 5-1 NMP2 EPU/M+ Power/Flow Map with 5% Voiding at the TIP ExitB ou n d ary ................................................................................................................
5-9Figure 9-1 L R N B P at IC F ......................................................................................................
9-26Figure 9-2 LRN BP at M ELLLA+ ..........................................................................................
9-27Figure 9-3 ODYN ATWS Analysis
-PRFO at EOC Short-Term Results ............................
9-28Figure 9-4 ODYN ATWS Analysis
-MSIVC at EOC Long-Term Results ..........................
9-29Figure 9-5 ODYN ATWS Analysis
-PRFO at EOC PCT ....................................................
9-30Figure 9-6 Single SLS Pump ODYN ATWS Analysis
-PRFO at EOC Short-Term R e su lts ..................................................................................................................
9 -3 1Figure 9-7 Single SLS Pump ODYN ATWS Analysis
-MSIVC at EOC Long-Term R e su lts ..................................................................................................................
9 -3 2Figure 9-8 Single SLS Pump ODYN ATWS Analysis
-PRFO at EOC PCT .......................
9-33Figure 9-9 ATWS Instability from MELLLA+ Operating Domain -Turbine Trip withF u ll B yp ass ...........................................................................................................
9-34vi NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Figure 9-10 ATWS Instability from MELLLA+ Operating Domain -Turbine Trip withF u ll B yp ass ...........................................................................................................
9-35Figure 9-11 ATWS Instability from MELLLA+ Operating Domain -Recirculation P u m p T rip .............................................................................................................
9-36Figure 9-12 ATWS Instability from MELLLA+ Operating Domain -Recirculation P u m p T rip .............................................................................................................
9-37vii NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)List of TablesTable Title PageTable 1-1 Computer Codes Used in the M+SAR Evaluations
..............................................
1-10Table 1-3 Core Thermal Power to Core Flow Ratios ............................................................
1-13Table 2-1 Peak N odal Exposures
..........................................................................................
2-17Table 2-2 Core Thermal Power to Core Flow Ratio at Steady-State and Off-Rated C o n d itio n s ............................................................................................................
2 -18Table 2-3 TLO and SLO DSS-CD Licensing Basis Generic Applicability EnvelopeC hecklist C onfirm ation ........................................................................................
2-19Table 2-4 [[.................
2-20Table 2-5 [[]]....................................................................................................
2 -2 1Table 3-1 K ey Results at 120% O LTP ..................................................................................
3-29Table 9-1 A OO Event Results Sum m ary ..............................................................................
9-17Table 9-2 Comparison of Slow Recirculation Flow Increase Results and MCPR FlowL im it .....................................................................................................................
9 -18Table 9-3 Key Input Parameters for ATWS Analyses
..........................................................
9-19Table 9-4 Key Results for Licensing Basis ODYN ATWS Analysis
...................................
9-20Table 9-5 ODYN ATWS Analysis Limiting Event Results at MELLLA+ ..........................
9-21Table 9-6 Key Input Parameters for Single SLS Pump ATWS Analyses
.............................
9-22Table 9-7 Key Results for Single SLS Pump ODYN ATWS Analysis
................................
9-23Table 9-8 Single SLS Pump ODYN ATWS Analysis Limiting Event Results ....................
9-24Table 9-9 Key Results for ATWS with Core Instability Analysis from MELLLA+O perating D om ain ................................................................................................
9-25viii NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)EXECUTIVE SUMMARYThis report summarizes the results of all significant safety evaluations (SEs) performed thatjustify the expansion of the core flow (CF) operating domain for the Nine Mile Point Unit 2(NMP2) nuclear plant. The changes expand the operating domain in the region of operation withless than rated core flow (RCF), but do not increase the licensed power level or the maximumCF. The expanded operating domain is identified as Maximum Extended Load Line LimitAnalysis Plus (MELLLA+).
The scope of evaluations required to support the expansion of the CF operating domain to theMELLLA+ boundary is contained in the Licensing Topical Report (LTR) NEDC-33006P-A, "Maximum Extended Load Line Limit Analysis Plus," referred to as the M+LTR (Reference 1).This report provides a systematic disposition of the M+LTR subjects applied to NMP2, including performance of plant-specific assessments and confirmation of the applicability of genericassessments to support a MELLLA+ CF operating domain expansion.
It is not the intent of this report to address all the details of the analyses and evaluations reportedherein. Only previously Nuclear Regulatory Commission (NRC)-approved or industry-accepted methods were used for the analyses of accidents and transients.
Therefore, because the safetyanalysis methods have been previously addressed, the details of the methods are not presented for review and approval in this report. Also, event and analysis descriptions that are alreadyprovided in other licensing reports or the updated safety analysis report (USAR) are not repeatedwithin this report.The MELLLA+ operating domain expansion is applied as an incremental expansion of theoperating boundary without changing the maximum licensed power or CF, or the current plantvessel dome pressure.
This report supports operation of NMP2 at current licensed thermal power(CLTP) of 3,988 MWt with CF as low as 85% RCF following implementation of the extendedpower uprate (EPU) at NMP2. The terms CLTP and EPU are used interchangeably throughout this document, and refer to the same power level of 3,988 MWt. The MELLLA+ core operating domain expansion does not require major plant systems modifications.
The core operating domain expansion involves changes to the operating power/core flow map, minor systemmodifications, procedure
: changes, and changes to a small number of instrument setpoints.
Because there are no increases in the operating
: pressure, power, steam flow rate, and feedwater (FW) flow rate, there are no significant effects on the plant systems outside of the nuclear steamsupply system (NSSS). There is a potential increase in the steam moisture content at certaintimes while operating in the MELLLA+ operating domain. The effects of the potential increasein moisture content on plant systems have been evaluated and determined to be acceptable.
TheMELLLA+ operating domain expansion does not cause additional requirements to be imposedon any of the safety, balance-of-plant (BOP), electrical, or auxiliary systems.
No changes to thepower generation and electrical distribution systems are required as a result of the MELLLA+operating domain expansion.
Evaluations of the reactor, engineered safety features (ESFs), power conversion, emergency power, support systems, environmental issues, and design basis accidents (DBAs) wereix NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)performed.
The following conclusions summarize the results of the evaluations presented in thisreport.* All safety aspects of the plant that are affected by MELLLA+ operating domainexpansion were evaluated.
* There is no change in the existing design basis and licensing basis acceptance criteria ofthe plant.* Evaluations were performed using NRC-approved or industry-accepted analytical methods." Where applicable, more recent industry codes and standards were used.* No major hardware modifications to safety-related equipment are required to supportMELLLA+ operating domain expansion.
" Systems and components affected by MELLLA+ were reviewed to ensure that there is nosignificant challenge to any safety system." Potentially affected commitments to the NRC were reviewed.
* Planned changes not yet implemented have also been reviewed for the effects ofMELLLA+.This report summarizes the results of the SEs needed to justify a licensing amendment to allowthe MELLLA+ operating domain expansion to a minimum CF rate of 85% of RCF at 100%CLTP. These SEs demonstrate that the MELLLA+ operating domain expansion can beaccommodated:
" without a significant increase in the probability or consequences of an accidentpreviously evaluated;
* without creating the possibility of a new or different kind of accident from any accidentpreviously evaluated; and" without exceeding any presently existing regulatory limits or acceptance criteriaapplicable to the plant that might cause a reduction in a margin of safety.Therefore, the requested MELLLA+ operating domain expansion does not involve a significant hazards consideration.
x NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)ACRONYMSTerm Definition 1 RPT One Recirculation Pump Trip2RPT Two Recirculation Pump TripABSP Automated Backup Stability Protection AC Alternating CurrentADS Automatic Depressurization SystemAL Analytical LimitALARA As Low As Reasonably Achievable ANS American Nuclear SocietyANSI American National Standards Institute AOO Anticipated Operational Occurrence AOP Abnormal Operating Procedure AOT Allowable Outage TimeAP Annulus Pressurization APRM Average Power Range MonitorARI Alternate Rod Insertion ARS Amplified Response SpectraART Adjusted Reference Temperature ARTS APRM / RBM / Technical Specifications ASME American Society of Mechanical Engineers AST Alternate Source Termatom % Percentage of AtomsATWS Anticipated Transient Without ScramAV Allowable ValueBOC Beginning of CycleBOP Balance-of-Plant BPV Boiler and Pressure VesselBSP Backup Stability Protection BSW Biological Shield WallBTU/Ibm BTU per Pounds MassBWR Boiling Water ReactorBWRVIP Boiling Water Reactor Vessel and Internals ProjectCDA Confirmation Density Algorithm CDF Core Damage Frequency xi NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Term Definition cfmn Cubic Feet per MinuteCENG Constellation Energy Nuclear GroupCF Core FlowCFR Code of Federal Regulations CLTP Current Licensed Thermal PowerCO Condensation Oscillation COLR Core Operating Limits ReportCPR Critical Power RatioACPR Change in Critical Power RatioCRD Control Rod DriveCRDA Control Rod Drop AccidentCRGT Control Rod Guide TubeCS Core SprayCST Condensate Storage TankDBA Design Basis AccidentDC Direct CurrentDFFR Dynamic Forcing Functions ReportD/G Diesel Generator DIR Design Input RequestDOR Division of Responsibility DRF Design Record FileDSS-CD Detect and Suppress Solution-Confirmation DensityDSS-CD LTR DSS-CD Licensing Topical ReportDSS-CD TRACG LTR DSS-CD TRACG Licensing Topical ReportDTR Draft Task ReportDW DrywellECCS Emergency Core Cooling SystemsEDG Emergency Diesel Generator EFPY Effective Full Power YearEOC End of CycleEOOS Equipment Out-of-Service EOP Emergency Operating Procedure EPRI Electric Power Research Institute EPU Extended Power UprateEQ Environmental Qualification xii NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Term Definition ESF Engineered Safety FeatureOF Degrees Fahrenheit FAC Flow Accelerated Corrosion FCV Flow Control ValveFHA Fuel Handling AccidentFIV Flow-Induced Vibration FTR Final Task ReportFW Feedwater FWCF Feedwater Controller Failure (Maximum Demand)FWHOOS Feedwater Heater(s)
Out-of-Service GEH GE-Hitachi Nuclear Energy Americas LLCGESTAR General Electric Standard Application for Reactor FuelGNF Global Nuclear Fuel -Americas LLCgpm Gallons Per MinuteGWd/ST Gigawatt Days per Short TonHCTL Heat Capacity Temperature LimitHELB High Energy Line BreakHFCL High Flow Control LineHPCI High Pressure Coolant Injection HPCS High Pressure Core SprayHVAC Heating, Ventilation, and Air Conditioning IASCC Irradiated Assisted Stress Corrosion CrackingICF Increased Core FlowID Internal DiameterIGSCC Intergranular Stress Corrosion CrackingILBA Instrument Line Break AccidentIPE Individual Plant Examination IPEEE Individual Plant Examination of External EventsIRM Intermediate Range MonitorISI In-Service Inspection JPSL Jet Pump Sensing LineLAR License Amendment RequestLCO Limiting Condition for Operation LCS Leakage Control SystemLERF Large Early Release Frequency xiii NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Term Definition LFWH Loss of Feedwater HeatingLHGR Linear Heat Generation RateLHGRFACf Linear Heat Generation Rate Flow FactorLOCA Loss-of-Coolant AccidentLOFW Loss of Feedwater LOOP Loss of Off-Site PowerLPCI Low Pressure Coolant Injection LPCS Low Pressure Core SprayLPRM Local Power Range MonitorLRNBP Generator Load Rejection Without BypassLTR Licensing Topical ReportMAPLHGR Maximum Average Planar Linear Heat Generation RateMCO Moisture Carryover MCPR Minimum Critical Power RatioMCPRr Flow-Dependent Minimum Critical Power RatioMCPR, Power-Dependent Minimum Critical Power RatioMCR Main Control RoomMELB Moderate Energy Line BreakMELC Moderate Energy Line CrackMELLLA Maximum Extended Load Line Limit AnalysisMELLLA+ Maximum Extended Load Line Limit Analysis PlusMFLPD Maximum Fraction of Limiting Power DensityMIP MCPR Importance Parameter M+LTR MELLLA+ Licensing Topical Report NEDC-33006P-A M+SAR MELLLA+ Safety Analysis Report (Plant Specific Safety Analysis Report)M+LTR SER MELLLA+ Safety Evaluation ReportMlbm/hr Millions Of Pounds Mass per HourMOC Middle of CycleMOP Mechanical Overpower MOV Motor-Operated ValveMPC Maximum Permissible Concentration MS Main SteamMSIV Main Steam Isolation ValveMSIVC Main Steam Isolation Valve ClosureMSIVF Main Steam Isolation Valve Closure with Scram on High Fluxxiv NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Term Definition MSL Main Steam LineMSLBA Main Steam Line Break AccidentMWd/ST Megawatt Days per Short TonMWe Megawatt-Electric MWt Megawatt-Thermal NCL Natural Circulation LineNMP2 Nine Mile Point Unit 2NMPNS Nine Mile Point Nuclear Station, LLCNPSH Net Positive Suction HeadNRC Nuclear Regulatory Commission NSSS Nuclear Steam Supply SystemNTSP Nominal Trip SetpointOBE Operating Basis Earthquake OLMCPR Operating Limit Minimum Critical Power RatioOLTP Original Licensed Thermal PowerOOS Out-of-Service OPRM Oscillation Power Range MonitorPCT Peak Cladding Temperature PDI Performance Demonstration Initiative ppm Parts per MillionPRA Probabilistic Risk Assessment PRFO Pressure Regulator Failure -Openpsi Pounds per Square Inchpsia Pounds per Square Inch -Absolutepsid Pounds per Square Inch -Differential psig Pounds per Square Inch -GaugePWP Project Work PlanQA Quality Assurance QAP Quality Assurance ProgramRAI Request for Additional Information RBM Rod Block MonitorRCF Rated Core FlowRCIC Reactor Core Isolation CoolingRCPB Reactor Coolant Pressure BoundaryRE Responsible Engineerxv NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Term Definition RG Regulatory GuideRHR Residual Heat RemovalRIPD Reactor Internal Pressure Difference RIS Regulatory Issue SummaryRLA Reload Licensing Analysisrpm Revolutions per MinuteRPS Reactor Protection SystemRPT Recirculation Pump TripRPTOOS Recirculation Pump Trip Out-of-Service RPV Reactor Pressure VesselRRS Reactor Recirculation SystemRSLB Recirculation Suction Line BreakRWCU Reactor Water CleanupRWE Rod Withdrawal ErrorRWM Rod Worth Minimizer SAD Amplitude Discriminator SetpointSAR Safety Analysis ReportSBO Station BlackoutSC Safety Communication SDC Shutdown CoolingSE Safety Evaluation SER Safety Evaluation ReportSGTS Standby Gas Treatment SystemSLMCPR Safety Limit Minimum Critical Power RatioSLO Single Loop Operation SLS Standby Liquid Control SystemSOP Special Operating Procedure SPC Suppression Pool CoolingSPDS Safety Parameter Display SystemSRLR Supplemental Reload Licensing ReportSRM Source Range MonitorSRO Strong Rod OutSRP Standard Review PlanSRV Safety Relief ValveSRVDL Safety Relief Valve Discharge Linexvi NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Term Definition SRVOOS Safety Relief Valve -Out-of-Service SSE Safe Shutdown Earthquake STP Simulated Thermal PowerTAF Top of Active FuelTBVOOS Turbine Bypass Out-of-Service TFW Feedwater Temperature TIP Traversing Incore ProbeTLO Two Loop Operation T-M Thermal-Mechanical TOP Thermal Overpower TR Topical ReportTS Technical Specifications TSD Task Scoping DocumentTSTF Technical Specification Task ForceTSV Turbine Stop ValveTTNBP Turbine Trip Without BypassTTWBP Turbine Trip With BypassUHS Ultimate Heat SinkUSAR Updated Safety Analysis ReportUSE Upper Shelf EnergyV&V Verification and Validation VPF Vane Passing Frequency wt.% Percent by Weightxvii NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)
==1.0 INTRODUCTION==
This report summarizes the results of all significant SEs performed that justify the expansion ofthe operating boundary to NMP2 operation at a CLTP of 3,988 MWt and with CF as low as 85%of RCF. The terms CLTP and EPU are used interchangeably throughout this document, andrefer to the same power level of 3,988 MWt. The changes expand the operating domain in theregion of operation with less than RCF, but do not increase the licensed power level or themaximum CF. The expanded operating domain is identified as MELLLA+.The scope of evaluations required to support the expansion of the CF operating domain to theMELLLA+ boundary is contained in the LTR NEDC-33006P-A, "Maximum Extended LoadLine Limit Analysis Plus," referred to as the M+LTR (Reference 1). This report provides asystematic disposition of the M+LTR subjects applied to NMP2, including performance of plant-specific assessments and confirmation of the applicability of generic assessments to support aMELLLA+ CF operating domain expansion.
The MELLLA+ core operating domain expansion does not require major plant hardwaremodifications.
In accordance with Limitation and Condition 12.2 of the NRC Safety Evaluation Report (SER) for MELLLA+ (Reference 1), referred to as the M+LTR SER, NMP2 willimplement the Detect and Suppress Solution-Confirmation Density (DSS-CD)
: solution, withlimitations and conditions as identified in the DSS-CD LTR SER (Reference 2), consistent withthe M+LTR. DSS-CD requires a revision to the existing stability solution software.
Theoperating domain expansion involves changes to the operating power/core flow map and changesto a small number of instrument setpoints.
Because there are no increases in the operating
: pressure, power, steam flow rate, and FW flow rate, there are no significant effects on the planthardware outside of the NSSS. There is a potential increase in the steam moisture content atcertain times while operating in the MELLLA+ operating domain. The effects of the potential increase in moisture content on plant hardware have been evaluated and determined to beacceptable.
The MELLLA+ operating domain expansion does not cause additional requirements to be imposed on any of the safety, BOP, electrical, or auxiliary systems.
No changes to thepower generation and electrical distribution systems are required due to the introduction ofMELLLA+.This report also addresses applicable limitations and conditions as described in the M+LTR SERand the NRC SER for the GE-Hitachi Nuclear Energy Americas LLC (GEH) LTRNEDC-33173P-A, "Applicability of GE Methods to Expanded Operating Domains,"
referred toas the Methods LTR SER (Reference 3).The disposition of each limitation and condition is discussed along with the relevant section ofthis report. A complete listing of the required M+LTR SER, Methods LTR SER, and DSS-CDLTR SER limitations and conditions and the sections of this report which address them ispresented in Appendices A, B, and C, respectively.
1-1 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)1.1 REPORT APPROACHThe evaluations provided in this report demonstrate that the MELLLA+ operating domainexpansion can be accomplished within the applicable safety design criteria.
Many of the SEs andequipment assessments previously performed for the NMP2 EPU are unaffected because theMELLLA+ operating domain expansion effects are limited to the NSSS system.This NMP2 MELLLA+ safety analysis report (M+SAR) follows the same structure and contentas the M+LTR (Reference 1). Two dispositions of the evaluation topics are used to characterize the MELLLA+ evaluation scope. Topics are dispositioned as either "Generic" or"Plant-Specific" as described in Sections
: 1. 1.1 and 1.1.2, respectively.
1.1.1 Generic Assessments Generic assessments are those SEs that can be dispositioned by:* Providing or referencing a bounding analysis for the limiting conditions;
" Demonstrating that there is a negligible effect due to MELLLA+;" Identifying the portions of the plant that are unaffected by the MELLLA+ power/flow map operating domain expansion; or* Demonstrating that the sensitivity to MELLLA+ is small enough that the required plantcycle-specific reload analysis process is sufficient and appropriate for establishing theMELLLA+ licensing basis in accordance with M+LTR SER Limitation andCondition 12.3.c and as defined in General Electric Standard Application for ReactorFuel (GESTAR)
(Reference 4).As per M+LTR SER Limitation and Condition 12.4, the plant-specific MELLLA+application shall provide the plant-specific thermal limits assessment and transient analysis results.
Considering the timing requirements to support the reload, the fuel andcycle-dependent analyses including the plant-specific thermal limits assessment may besubmitted by supplementing the initial M+SAR. Additionally, the Supplemental ReloadLicensing Report (SRLR) for the initial MELLLA+ implementation cycle shall besubmitted for NRC staff confirmation.
Some of the SEs affected by MELLLA+ are fuel operating cycle (reload) dependent.
Reload dependent evaluations require that the reload fuel design, core loading pattern,and operational plan be established so that analyses can be performed to establish coreoperating limits. The reload analysis demonstrates that the core design for MELLLA+meets the applicable NRC evaluation criteria and limits documented in Reference 4.1-2 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)]] No plant can enter the MELLLA+ domain unless the appropriate reload core analysis is performed and all criteria and limits documented in Reference 4are satisfied.
Otherwise, the plant would be in an unanalyzed condition.
Based oncurrent requirements, the reload analysis results are documented in the SRLR, and theapplicable core operating limits are documented in the plant-specific Core Operating Limits Report (COLR).NMP2 will supplement this M+SAR with the fuel and cycle dependent analysis including the plant-specific thermal limits assessment.
Additionally, NMP2 will submit the SRLRfor the initial MELLLA+ implementation cycle for NRC staff confirmation.
As required by M+LTR SER Limitation and Condition 12.5.a, Nine Mile Point NuclearStation, LLC (NMPNS) will modify NMP2 Technical Specification (TS) 3.4.1 to includea requirement that prohibits intentional single loop operation (SLO) while in theMELLLA+ operating domain, as defined in the COLR. This information is presented inthe NMPNS MELLLA+ license amendment request (LAR) for NMP2.As required by M+LTR SER Limitation and Condition 12.3.b, the applicability of thegeneric assessments to NMP2 is identified and confirmed in the applicable sections.
Inthe event that the generic assessment presented in the M+LTR is not applicable to NMP2,a plant-specific evaluation per Section 1. 1.2 is completed to demonstrate the acceptability of the MELLLA+ operating domain expansion.
1.1.2 Plant-Specific Evaluation A NMP2-specific evaluation is provided for SEs not categorized as Generic.
Where applicable, the assessment methodology in References 1, 4, 5, 6, or 7 is referenced.
As required by M+LTRSER Limitation and Condition 12.3.a, the plant-specific evaluations performed and reported inthis document use plant-specific values to model the actual plant systems, transient
: response, andcurrent operating conditions.
1.1.3 Computer Codes and MethodsNRC-approved or industry-accepted computer codes and calculational techniques are used in theevaluations for the MELLLA+ operating domain. The primary computer codes used for NMP2evaluations are listed in Table 1-1. The application of these codes complies with the limitations, restrictions, and conditions specified in the approving NRC SER. Exceptions to the use of thecode or special conditions of the applicable SER are included as notes to Table 1-1.The Methods LTR NEDC-33173P-A (Reference
: 3) documents all analyses supporting theconclusions in this section that the application ranges of GEH codes and methods are adequate inthe MELLLA+ operating domain. In accordance with the M+LTR SER Limitation andCondition
: 12. 1, the range of mass fluxes and power/flow ratios in the GEXL database covers theintended MELLLA+ operating domain. The database includes low flow, high qualities, and voidfractions.
There are no restrictions on the application of the GEXL-PLUS correlation in theMELLLA+ operating domain.1-3 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)As required by M+LTR SER Limitation and Condition 12.23.2, the NMP2-specific ODYN andTRACG calculations are provided to the NRC as required.
As discussed in Section 1.0, the specific limitations and conditions associated with the M+LTR,Methods LTR, DSS-CD LTR, and DSS-CD TRACG LTR are discussed along with the relevantsection of this report. A complete listing of the required M+LTR SER, Methods LTR SER, andDSS-CD LTR SER limitations and conditions and the sections of this report which address themis presented in Appendices A, B, and C, respectively.
1.1.4 Scope of Evaluations Sections 2.0 through 11.0 provide evaluations of the MELLLA+ operating domain expansion onthe respective topics. The scope of the evaluations is summarized in the following sections.
Section 2.0, Reactor Core and Fuel Performance:
Core and fuel performance parameters areconfirmed for each fuel cycle, and will be evaluated and documented in the SRLR and COLR foreach fuel cycle that implements the MELLLA+ operating domain.Section 3.0, Reactor Coolant and Connected Systems:
Evaluations of the NSSS components and systems are performed in the MELLLA+ operating domain. Because the reactor operating pressure and the CF are not increased by MELLLA+,
the effects on the Reactor Coolant andconnected systems are minor. These evaluations confirm the acceptability of the MELLLA+changes to process variables in the NSSS.Section 4.0, Engineered Safety Features:
The effects of MELLLA+ operating domainexpansion on the containment, emergency core cooling systems (ECCS), standby gas treatment system (SGTS), and other ESFs are evaluated.
The operating pressure for ESF equipment is notincreased because operating pressure and safety relief valve (SRV) setpoints are unchanged as aresult of MELLLA+.Section 5.0, Instrumentation and Control:
The instrumentation and control systems andanalytical limits (ALs) for setpoints are evaluated to establish the effects of MELLLA+ operating domain expansion on process parameters.
The scope of MELLLA+ effects on the controls andsetpoints is limited because the MELLLA+ parameter variations are limited to the core.Section 6.0, Electrical Power and Auxiliary Systems:
Because the power level is not changedby MELLLA+,
the electrical power and distribution systems are not affected.
The auxillary systems have been previously evaluated to ensure they are capable of supporting safe plantoperation at CLTP, which is unchanged by MELLLA+ operating domain expansion.
Section 7.0, Power Conversion Systems:
Because the pressure, steam flow, and FW flow donot change as a result of MELLLA+ operating domain expansion, the power conversion systemsare not affected by MELLLA+.Section 8.0, Radwaste Systems and Radiation Sources:
The liquid and gaseous wastemanagement systems are not affected by the MELLLA+ operating domain changes.
However,slightly higher loading of the condensate demineralizers is possible if the moisture carryover (MCO) in the reactor steam increases.
The radiological consequences are evaluated to show thatapplicable regulations are met.1-4 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Section 9.0, Reactor Safety Performance Evaluations:
The USAR anticipated operational occurrences (AOOs), DBAs, and special events are reviewed as part of the MELLLA+evaluation.
Section 10.0, Other Evaluations:
High energy line break (HELB) and environmental qualification (EQ) evaluations for the MELLLA+ domain are confirmed to demonstrate theoperability of plant equipment at MELLLA+ conditions.
The effects on the individual plantexamination (IPE) are evaluated to demonstrate there is no significant change to the NMP2vulnerability to severe accidents.
Section 11.0, Licensing Evaluations:
This section includes the effect on TS. TheEnvironmental Assessment and the No Significant Hazards Consideration are provided as a partof the accompanying LAR.1.1.5 Product Line Applicability The M+LTR describes processes, evaluations, and dispositions applicable to GE boiling waterreactor (BWR) product lines BWR/3, BWR/4, BWR/5, and BWRI6. As such, the M+LTRprocess is applicable to NMP2, a BWR/5.1.1.6 Report Generation and Review ProcessThis M+SAR represents several years of project planning activities, engineering
: analysis, technical verification, and technical review. The final stages of the M+SAR preparation includeM+SAR integration, additional review, on-site review committee review, and submittal to NRC.The NMP2 MELLLA+ project relied on the generic M+LTR (Reference
: 1) submitted to andapproved by the NRC (Reference 1).The project began with the respective GEH and NMPNS Project Managers creating a ProjectWork Plan (PWP). This PWP, developed in accordance with GEH engineering procedures, wasused to define the plant-specific work scope, inputs and outputs required for project activities.
Adivision of responsibility (DOR) between NMPNS and GEH was used to further develop thework scope and assign responsible engineers (REs) from each organization.
A task scopingdocument (TSD) applicable for each GEH task was created,
: reviewed, and approved by NMPNSprior to any technical work being performed.
Each GEH task RE submitted a design inputrequest (DIR) to the NMPNS task RE interface to define the correct plant information for use inthe GEH task analysis and evaluation.
Additional DIRs were submitted as the project continued.
A plant-specific M+SAR "shell" was created that contains the appropriate depth of information expected in the final M+SAR.All pertinent information is captured in an individual task design record file (DRF) maintained by the GEH RE with oversight by the respective engineering manager.
Each DRF contains thequality assurance records applicable to the task, which includes evidence of design verification.
A draft task report (DTR) was created for every GEH task. The DTR includes a description ofthe analysis performed, inputs, methods applied, results obtained and includes input to theapplicable M+SAR section(s).
The DTR with M+SAR input was verified, in accordance withthe GEH quality assurance program (QAP), by a GEH technical verifier and a GEH Regulatory 1-5 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Affairs verifier, with oversight by the responsible GEH technical manager and GEH ProjectManager.
The DTR with M+SAR input was transmitted by the GEH Project Manager toNMPNS and reviewed by the NMPNS RE and other NMPNS engineers, as appropriate.
Subsequent comments were resolved between the GEH and the NMPNS REs and a final taskreport (FTR) with M+SAR input was developed.
The FTR with M+SAR input was againverified (whether or not there were changes to the document),
in accordance with the GEH QAP,by a GEH technical verifier and a GEH Regulatory Affairs verifier, with oversight by theresponsible GEH technical manager and GEH Project Manager.
The GEH Project Managertransmitted the FTR with M+SAR input to the NMPNS Project Manager.For the NMP2 MELLLA+ project, NMPNS personnel:
: 1. Conducted multidisciplinary technical reviews of GEH evaluation reports (DTRswith M+SAR input and FTRs with M+SAR input) to ensure:i. Appropriate use of design inputs;ii. Consistency with the M+LTR; andiii. Design basis and licensing basis requirements were addressed.
: 2. Provided technical review results, in the form of detailed
: comments, to GEHperformers;
: 3. Participated in discussions with GEH REs to address and resolve comments; and4. Controlled the application of the NMPNS off-site services process to GEH.The Regulatory Affairs RE integrated the individual M+SAR sections creating a Draft M+SARthat was verified, in accordance with the GEH QAP, by another GEH Regulatory Affairsengineer, with oversight by the GEH Regulatory Affairs Services Licensing Manager and theGEH Project Manager.
The GEH Project Manager transmitted the verified Draft M+SAR toNMPNS where it received another complete review by NMPNS's technical personnel, projectstaff, and Licensing staff.NMPNS personnel generated questions and comments, which were responded to by GEH'stechnical and Regulatory Affairs personnel.
The M+SAR was then presented to the NMPNS'son-site review committee.
After resolution of any final comments, the Final M+SAR wassubmitted to the NRC.A technical assessment of GEH's work was performed during reviews conducted at GEH officesin Wilmington, NC during January 2011. The scope of these assessments included workperformed by GEH and Global Nuclear Fuel -Americas LLC (GNF) in support of the NMP2MELLLA+ project.
Participating in those activities were representatives of NMP2mechanical/structural,
: nuclear, and reactor engineering disciplines, and project engineering.
TheNMP2 team reviewed design inputs, analysis methodologies, and results in the GEH DRFs. Thereviews included discussion with GEH technical task performers to obtain a thoroughunderstanding of GEH analysis methods.1.1.7 Report Generation and Review ProcessAs noted in Section 1.1.6 above, a DOR between NMPNS and GEH was used to further developthe work scope and assign REs from each organization.
Tasks assigned to NMPNS REs were1-6 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)performed under the NMPNS 10 Code of Federal Regulations (CFR) 50, Appendix B QAP,where applicable.
The NMPNS assigned tasks were performed internally by NMPNS engineers or contracted out to engineering consulting firms on the NMPNS approved supplier list. Whereapplicable, the contractors applied a 10 CFR 50 Appendix B QAP.NMPNS internal tasks were prepared,
: reviewed, and approved in accordance with applicable procedures.
For contracted tasks, a TSD applicable for each task was created,
: reviewed, and approved byNMPNS prior to any technical work being performed.
This work scope formed the basis for theMELLLA+ task. The design inputs were then collected,
: reviewed, and forwarded to theengineering consultant, in accordance with applicable procedures.
FTRs, and other engineering
: products, when issued, are processed through the NMPNSengineering change process as a final verification of acceptability and retained as a quality recordin the NMPNS nuclear records management system.1.2 OPERATING CONDITIONS AND CONSTRAINTS 1.2.1 Power/Flow MapThe NMP2 power/flow map including the MELLLA+ operating domain expansion is shown inFigure 1-1. [[All lines on the power/flow map in Figure 1-1, other than those associated with the MELLLA+operating domain expansion, are unchanged by MELLLA+.As required by M+LTR SER Limitation and Condition 12.5.c, NMP2 will include thepower/flow map in the COLR after the MELLLA+ operating domain expansion is approved.
The MELLLA+ domain extends from 55% RCF at 77.6% EPU to 85% RCF at 100% EPU.Normal core performance characteristics for plant power/flow maneuvers at near full power canbe accomplished above 55% CF. Due to stability considerations at high power and low CF, theMELLLA+ domain was not extended below 55% RCF. The reactor operating conditions following an unplanned event could stabilize at a power/flow point outside the allowed operating domain. If this occurs the operator must reduce power or increase flow in accordance with plantprocedures to place the plant back into the allowed operating domain.The steady-state core thermal power to CF ratio for operation in the MELLLA+ domain is listed inTable 1-3. Each point listed is in compliance with the Methods LTR SER Limitation andCondition 9.3 of 50 MWt/Mlbmihr with the exception of the point of low flow/ high power, point'M' (55% RCF / 77.6% EPU), on Figure 1-1. The point on the power/flow map is only marginally above the limit and is not used for extended periods of operation.
Because the limitation is notintended to place operational restrictions on the plant (Reference 3.c), the NMP2 MELLLA+power/flow map shall remain as shown in Figure 1-1, without any additional restrictions.
1-7 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)As NMP2 exceeds the power-to-flow ratio of 50 MWt/Mlbm/hr at 55% RCF, an assessment of thelimitation with respect to the conservatism of the power distribution uncertainties is performed.
Theresults of this assessment are provided in Section 2.2.5.1.2.2 Reactor Heat BalanceThe reactor heat balance is affected.
Operation in the MELLLA+ domain, with lower CF, results ina decrease in recirculation pump heat and core inlet enthalpy.
1.2.3 Core and Reactor Conditions As mentioned previously, the MELLLA+ operating domain expansion results in changes to thecore and reactor.Table 1-2 compares Maximum Extended Load Line Limit Analysis (MELLLA) and MELLLA+thermal-hydraulic operating conditions for NMP2. The differences shown in Table 1-2 aretypical of other BWR plants analyzed for MELLLA+ operating domain expansion, and the coreoperating conditions listed in Table 1-3 represent the maximum allowed power-to-flow ratiostatepoints within the boundaries of the MELLLA+ operating domain. [[]]The decay heat is principally a function of the reactor power level and the irradiation time. TheMELLLA+ operating domain expansion does not alter either of these two parameters, andtherefore, there is no first order effect on decay heat. Enrichment,
: exposure, void fraction, powerhistory, cycle length, and refueling batch fraction have a second order effect on decay heat.1]1.2.4 Operational Enhancements The following table provides the performance improvement and/or equipment out-of-service (EOOS) features applicable to NMP2 and whether they are allowed in the MELLLA+ operating domain. The table also dispositions other operational enhancements that were discussed in theM+LTR (Reference 1).Operational Enhancements MELLLA+ NMP2 M+SARIncreased Core Flow (ICF) Allowed IncludedSingle Loop Operation Not Allowed Not IncludedSafety Relief Valve -Out-of-Service (SRVOOS)
(2 valves) Allowed IncludedAverage Power Range Monitor (APRM) / Rod Block Allowed IncludedMonitor (RBM) / Technical Specifications (ARTS)Recirculation Pump Trip Out-of- Service (RPTOOS)
Allowed Included1-8 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Turbine Bypass Out-of-Service (TBVOOS)
Allowed IncludedMain Steam Isolation Valve (MSIV) Out-of-Service (OOS) Allowed IncludedTwo Automatic Depressurization System (ADS) Valves Out- Allowed Includedof-Service 20'F FW Operational Temperature Band Allowed Included24 Month Cycle Allowed Included60-Year Plant Life Allowed IncludedThe evaluations performed in support of MELLLA+ operating domain expansion consider eachof the operational enhancements listed as "Allowed."
Because the operational enhancements areconsidered as a part of the design inputs for evaluations performed in support of MELLLA+operating domain expansion, these operational enhancements are evaluated across the scope ofthis M+SAR and are therefore not dispositioned in a specific section.The existing NMP2 License Condition 7 restricts operation with FW heating to within20 degrees of the design FW temperature which satisfies M+LTR SER Limitation andCondition 12.5.b.SLO in the MELLLA+ domain is not proposed.
The present licensing basis for SLO remainsapplicable per plant TS.As required by M+LTR SER Limitation and Condition 12.5.a, NMPNS will modify NMP2TS 3.4.1 to include a requirement that prohibits intentional SLO operation while in theMELLLA+ operating domain as defined in the COLR. This information is presented in theNMPNS MELLLA+ LAR for NMP2.1.3 SUMMARY AND CONCLUSIONS This M+SAR documents the results of analyses necessary to expand the operating domain of theNMP2 plant to include the MELLLA+ domain. This document conforms to the scope, contentand structure described in the M+LTR, which the NRC has determined "is acceptable forreferencing in licensing applications for GE-designated boiling water reactors to the extentspecified and under the limitations and conditions delineated in the TR [topical report] and in theenclosed final SE [safety evaluation]."
1-9 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Table 1-1 Computer Codes Used in the M+SAR Evaluations Task Computer Version or NRC CommentsCode* Revision ApprovedReactor Heat Balance ISCOR 09 Y(l) NEDE-2401 IP Rev. 0 SERReactor Core and Fuel TGBLA 06 Y(2) NEDE-30130P-A Performance PANACEA 11 Y(2) NEDE-30130P-A ISCOR 09 Y(l) NEDE-240I P Rev. 0 SERPRIME 03 Y(17) NEDC-33256P-A Revision I,NEDC-33257P-A Revision 1,NEDC-33258P-A Revision 1Thermal Hydraulic Stability ODYSY 05 Y NEDC-33213P-A TRACG 04 Y(14) NEDE-33147P-A Rev. 4ISCOR 09 Y(l) NEDE-2401 IP Rev. 0 SERPANACEA II Y(3) NEDE-30130P-A Reactor Internal Pressure LAMB 07 (4) NEDE-20566P-A, September 1986Differences TRACG 02 Y(5) NEDE-32176P, Rev. 0, February 1993NEDE-32177P, Rev. 1, June 1993NRC TAC No. M90270, Sept. 1994ISCOR 09 Y(l) NEDE-2401 1P Rev. 0 SERReactor Recirculation BILBO 04V (8) NEDE-23504, Feb. 1977System (RRS)Reactor Pressure Vessel TGBLA 06 Y(2) NEDE-30130P-A (RPV) Fluence DORTG 01 Y(l 1, 12) CCC-543Containment System M3CPT 05 Y NEDO-10320, April 1971 (Reference 8)Response and NUREG-0808 (Reference 9)NEDE-20566P-A, September 1986LAMB 08 (4) (Reference 10)Break Flow Mass/Energy TRACG 04 N(I 5) NEDE-32176P Rev. 4, January 2008Release Rates NEDE-32177P Rev. 3, August 2007NEDO-33083-A Rev. 1, September 2010Annulus Pressurization (AP) ISCOR 09 Y(l) NEDE-2401 IP Rev. 0 SERLoads GOTHIC 7.2b N(16)AP Loads -RPV and SAP4G 07 N(8) NEDO-10909, Rev. 7, December 1979Internals' Structural SPECA 05 N(8) NEDE-25181, August 1996Analysis PDA 02 N(8) NEDE-10813A, February 1976ECCS-Loss-of-Coolant LAMB 08 Y NEDE-20566P-A Accident (LOCA) PRIME 01 Y(17) NEDC-33256P-A, Rev. 101 Y NEDC-33257P-A, Rev. 101 Y NEDC-33258P-A, Rev. ISAFER 04 Y (9) (10)ISCOR 09 Y(l) NEDE-2401 IP Rev. 0 SERTASC 03 Y NEDC-32084P-A 1-10 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Task Computer Version or NRC CommentsCode* Revision ApprovedTransient Analysis PANACEA 11 Y NEDE-30130P-A (6)ODYN 09 Y NEDE-24154P-A (Reference Ii)NEDC-24154P-A, Vol. 4, Sup I(Reference 11)ISCOR 09 Y(1) NEDE-2401 IP Rev. 0 SERTASC 03 Y NEDC-32084P-A Rev. 2Anticipated Transient ODYN 09 Y NEDC-24154P-A, Vol. 4, Sup. IWithout Scram (ATWS) STEMP 04 (7)PANACEA 11 Y(6)TASC 03A Y NEDC-32084P-A Rev. 2ISCOR 09 Y(l) NEDE-2401 IP Rev. 0 SERTRACG 04 N(I 3) 1__The application of these codes to the MELLLA+ analyses complies with the limitations, restrictions, andconditions specified in the approving NRC SER where applicable for each code. The application of the codesalso complies with the SERs for the MELLLA+ programs.
Notes for Table 1-1:(1) The ISCOR code is not approved by name. However, in the SER supporting approval of NEDE-2401 1PRevision 0 by the May 12, 1978 letter from D. G. Eisenhut (NRC) to R. Gridley (GE), the NRC finds themodels and methods acceptable for steady-state thermal-hydraulic
: analysis, and mentions the use of a digitalcomputer code. The referenced digital computer code is ISCOR. The use of ISCOR to provide corethermal-hydraulic information in reactor internal pressure differences (RIPDs),
transient, ATWS, stability, and LOCA applications is consistent with the approved models and methods.(2) The use of TGBLA Version 06 and PANACEA Version 11 was initiated following approval of Amendment 26 of GESTAR II by letter from S. A. Richards (NRC) to G. A. Watford (GE)
==Subject:==
"Amendment 26 toGE Licensing Topical Report NEDE-2401 1P-A, GESTAR II Implementing Improved GE Steady-State Methods (TAC NO. MA648 1)," November 10, 1999.(3) The use of PANACEA Version 11 was initiated following approval of Amendment 26 of GESTAR II byletter from S. A. Richards (NRC) to G. A. Watford (GE)
==Subject:==
"Amendment 26 to GE Licensing TopicalReport NEDE-24011P-A, GESTAR II Implementing Improved GE Steady-State Methods,"
(TACNO. MA6481),
November 10, 1999.(4) The LAMB code is approved for use in ECCS-LOCA applications (NEDE-20566P-A),
but no approving SERexists for the use of LAMB for the evaluation of RIPDs or containment system response.
The use of LAMBfor these applications is consistent with the model description of NEDE-20566P-A.
(5) NRC has reviewed and accepted the TRACG application for the flow-induced loads on the core shroud asstated in NRC SER TAC No. M90270.(6) The physics code PANACEA (PANAC) provides inputs to the transient code ODYN. The use of PANACEAVersion 11 in this application was initiated following approval of Amendment 26 of GESTAR II by letterfrom S. A. Richards (NRC) to G. A. Watford (GE)
==Subject:==
"Amendment 26 to GE Licensing Topical Report1-11 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)NEDE-2401 I P-A, GESTAR II Implementing Improved GE Steady-State Methods,"
(TAC NO. MA648 1),November 10, 1999.(7) The STEMP code uses fundamental mass and energy conservation laws to calculate the suppression poolheatup. The use of STEMP was noted in NEDE-24222, "Assessment of BWR Mitigation of ATWS,Volume I & II (NUREG-0460 Alternate No. 3) December 1, 1979." The code has been used in ATWSapplications since that time. There is no formal NRC review and approval of STEMP or the ATWS TR.(8) Not a safety analysis code that requires NRC approval.
The code application is reviewed and approved byGEH for "Level-2" application and is part of GEH's standard design process.
The application of this codehas been used in other MELLLA+ and power uprate submittals.
(9) "SAFER Model for Evaluation of Loss-of-Coolant Accidents for Jet Pump and Non-Jet Pump Plants,"NEDE-30996P-A, General Electric
: Company, October 1987.(10) Letter, Richard E. Kingston (GEH) to NRC, "Transmittal of Revision 1 of NEDC-32950, Compilation ofImprovements to GENE's SAFER ECCS-LOCA Evaluation Model," MFN 07-406, July 31, 2007.(11) CCC-543, "TORT-DORT Two- and Three-Dimensional Discrete Ordinates Transport Version 2.8.14,"Radiation Shielding Information Center (RSIC), January 1994.(12) The use of DORTG was approved by the NRC through the letter from H. N. Berkow (NRC) to G. B.Stramback (GE), "Final Safety Evaluation Regarding Removal of Methodology Limitations forNEDC-32983P-A, General Electric Methodology for Reactor Pressure Vessel Fast Neutron Flux Evaluations (TAC No. MC3788),"
November 17, 2005.(13) The TRACG04 code is not approved by the NRC for long-term ATWS calculations including ATWS withdepressurization and ATWS with core instability.
: However, TRACG04 is used as a best-estimate code, whileODYN remains as the licensing basis code for ATWS consistent with the NRC SE for NEDC-33006P.
Theuse of TRACG04 for the best-estimate TRACG ATWS analysis is also consistent with the NRC SE forNEDC-33006P.
TRACG04 is approved by the NRC for application to ATWS overpressure transients inNEDE-32906P Supplement 3-A, "Migration to TRACGO4 / PANAC 1I from TRACG02 / PANAC1O forTRACG AOO and ATWS Overpressure Transients,"
April 2010.(14) The TRACG04 application for DSS-CD is documented in NEDE-33147P-A Revision 4 (Reference 12).(15) The TRACG break flow model and qualification basis is described in NEDE-32176P and NEDE-32177P.
The application of TRACG04 for the calculation of break flow mass/energy release rates has been approvedfor ESBWR LOCA application in NEDO-33083-A.
(16) GOTHIC quality assurance (QA) Version 7.2b has been applied in several NRC approved primarycontainment/subcompartment evaluation analyses including the NMP2 EPU peak pressure evaluations toaddress GEH Safety Communication (SC) 09-05 submitted on October 8, 2010 (Reference 13). Theassociated NRC SER for the NMP2 EPU LAR was issued on December 22, 2011 (Reference 14).(17) Application of PRIME models and data to downstream methods is approved by NEDO-33173 Supplement 4-A, "Implementation of PRIME Models and Data in Downstream Methods,"
Revision 1,November 2012 (Reference 3).1-12 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Table 1-2 Comparison of Thermal-Hydraulic Parameters MELLLA MELLLA+ MELLLA+Parameter 100% CLTP, 100% CLTP, 77.6% CLTP,99% Core Flow 85% Core Flow 55% Core FlowThermal Power (MWt) 3988 3988 3095Dome Pressure (psia) 1035 1035 1011Steam Flow Rate (Mlbm/hr) 17.636 17.633 13.115FW Flow Rate (Mlbm/hr) 17.604 17.601 13.083FW Temperature
('F) 440.5 440.5 411.4Core Flow (Mlbrn/hr) 107.4 92.2 59.7Core Inlet Enthalpy (BTU/Ibm) 528.7 525.2 511.4Core Pressure Drop (psi) 25.0 20.2 10.7Core Average Void Fraction 0.504 0.531 0.532Core Exit Void Fraction 0.723 0.755 0.766Table 1-3 Core Thermal Power to Core Flow RatiosPoint on the Core Thermal Core Flow Power-to-Flow Steady-State Operation Power/Flow Power RatioMap (MWt/%CLTP)
(Mlbm/hr/%rated)
(MWt/Mlbm/hr)
Current Operating Domain E 3988 /100 108.5 /100 36.76100% Rated Core FlowCurrent Operating Domain D 3988 / 100 107.4/99 37.1399% Rated Core FlowMELLLA+Operating Domain N 3988 /100 92.2 / 85 43.2485% Rated Core FlowMELLLA+Operating Domain M 3095 / 77.6 59.7 / 55 51.8655% Rated Core Flow1-13 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Core Flow (Mlbm/hr) 0 10 20 30 40 50 60 7080 90 100 110 120 1301201101009080f"7060so3020100100% CLTP = 3988 MWt86.9% CLTP (Pre-EPU) 3467 MWt100% Core Flo1 = 108.5 Mlbrn/hr450040003500300025002000 Ei150010005000 10 20 30 40 50 60 70 80 90 100 110 120Core Flow (%)Figure 1-1 Power/Flow Operating Map for MELLLA+1-14 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)2.0 REACTOR CORE AND FUEL PERFORMANCE This section addresses the evaluations that are applicable to MELLLA+.Because NMP2 currently uses only GE14 fuel, the following limitations and conditions from theMethods LTR SER and M+LTR SER are not applicable to the NMP2 M+SAR:Methods LTR SER Limitations and Conditions:
APPLICATION OF 10 WEIGHT PERCENT GD: Limitation and Condition 9.13MIXED CORE METHOD 1: Limitation and Condition 9.21MIXED CORE METHOD 2: Limitation and Condition 9.22M+LTR SER Limitations and Conditions:
CONCURRENT CHANGES:
Limitations and Conditions 12.3.d, 12.3.e, and 12.3.fAPPENDIX
-A Request for Additional Information (RAI) 14-9: Limitation andCondition 12.23.6APPENDIX
-A RAI 14-10: Limitation and Condition 12.23.72.1 FUEL DESIGN AND OPERATION The effect of MELLLA+ on the fuel design and operation is described below. The topicsaddressed in this evaluation are:M+LTRTopic Disposition NMP2 ResultFuel Product Line Design [[Core DesignFuel Thermal Margin Monitoring Threshold
]]2.1.1 Fuel Product LineThe fuel design limits are established for all new fuel product line designs as a part of the fuelintroduction and reload analyses.
The M+/-LTR establishes that there are no changes in fuelproduct line design as a consequence of MELLLA+.
Because implementation of the MELLLA+operating domain does not necessitate a new fuel design, no additional fuel and core designevaluation is required.
NMP2 currently operates with GEl4 fuel. The cycle in which MELLLA+ operating domainexpansion is implemented shall contain GEl4 fuel. [[]] no new fuel product line design is introduced, and there is no change to fueldesign limits required by the MELLLA+ introduction at NMP2. Therefore, the SRLR willconfirm that there are no new fuel products as a result of MELLLA+ and will validate theconclusion that no additional fuel and core design evaluation is required for NMP2.2-1 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)2.1.2 Core Design and Fuel Thermal Monitoring Threshold
[[]] the maximum licensed power level and fuel design do not changeas a result of MELLLA+.
[[ ]]there is no change to the average power density as a result of MELLLA+ operating domainexpansion.
Because the maximum licensed power level and fuel design do not change as a resultof MELLLA+,
there is no increase in the average bundle power. Because there is no change inaverage power density, there is no change required to the fuel thermal monitoring threshold.
[[ ]] there are no changes to the NMP2fuel or fuel design limits as a result of MELLLA+.
NMP2 continues to use GEl4 fuel. TheCLTP remains at 3,988 MWt. This validates the conclusion that there are no changes needed tothe fuel thermal monitoring threshold for NMP2.Furthermore, because the MELLLA+ operating domain allows higher bundle power versus flowconditions,
[[ ]] the range of void fraction, axialand radial power shape, and rod positions in the core may change slightly.
The change in powerdistribution in the core is achieved, while the individual fuel bundles remain within the allowable thermal limits as defined in the COLR.Also, [[ ]], and per Methods LTR SER Limitation andCondition 9.17, the range of void fraction, axial and radial power shape, and rod positions in thecore does change slightly as a result of MELLLA+ operating domain expansion.
For NMP2, thepredicted bypass void fraction at the D-Level local power range monitor (LPRM) satisfied the[[ ]] design requirement.
The cycle-specific SRLR will confirm that the void fraction is< 5% according to Methods LTR SER Limitation and Condition 9.17. The table below showsthat steady-state bypass voiding is demonstrated on the MELLLA+ upper boundary at 100%power.% of Rated Core % of Rated Hot Channel Void Fraction in Bypass Region atItemPower Core Flow Instrumentation D Level (ISCOR Node 21)1 100 99 1.6%2 100 85 3.0%As required by Methods LTR SER Limitation and Condition 9.24, the following core design andfuel monitoring parameters are plotted as indicated below in Table 2-1 and Figures 2-1 through2-6 for each cycle exposure statepoint.
The parameters are compared to the experience basereported in Reference 3:Table 2-1 Peak Nodal Exposures Figure 2-1 Power of Peak Bundle versus Cycle ExposureFigure 2-2 Coolant Flow for Peak Bundle versus Cycle ExposureFigure 2-3 Exit Void Fraction for Peak Power Bundle versus Cycle Exposure2-2 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Figure 2-4 Maximum Channel Exit Void Fraction versus Cycle ExposureFigure 2-5 Core Average Exit Void Fraction versus Cycle ExposureFigure 2-6 Peak LHGR versus Cycle ExposureAs part of the information requested for M+LTR SER Limitation and Condition 12.24.2, the exitvoid fraction for peak power bundle versus cycle exposure is provided in Figure 2-3.Also, quarter core maps with mirror symmetry are plotted in Figure 2-7 through Figure 2-15showing bundle power, bundle operating linear heat generation rate (LHGR), and minimumcritical power ratio (MCPR) for beginning of cycle (BOC) (0.2 GWd/ST),
middle of cycle(MOC) (10.0 GWd/ST),
and end of cycle (EOC) (18.577 GWd/ST).
The maximum fraction oflimiting power density (MFLPD) occurs at 15.0 GWd/ST (Figure 2-16) and the largest maximumfraction of limiting critical power ratio (MFLCPR) occurs at 1.5 GWd/ST (Figure 2-17) for thiscore design. In Figure 2-7 through Figure 2-9, the bundle power is dimensionless.
To obtain thebundle power in MWt, multiply each number by the average power per bundle. Prior to EOC,the average power per bundle is 5.2199; this factor equals 3,988/764, where 3,988 MWt is theRTP and 764 is the total number of fuel bundles in the core. At EOC, the average power perbundle is 4.6648.Table 2-1 shows that NMP2's Peak Nodal Exposure are lower than the top four reference plants.Figures 2-1 through 2-4 and Figure 2-6 show NMP2 MELLLA+ operation is in the expectedrange as compared to the reference plants. Figure 2-5 shows that NMP2 is higher than all theother plants. This is because of NMP2 MELLLA+ operating conditions, which are at full EPUpower and 85% flow, while the available data for other plants are not at full EPU and/orMELLLA+ conditions.
Figures 2-7 through 2-9 show the relative bundle power for BOC, MOC,and EOC, respectively.
Figures 2-10 through 2-12 show the operating LHGR for BOC, MOC,and EOC, respectively.
Figures 2-13 through 2-15 show the MCPR for BOC, MOC, and EOC,respectively.
Figures 2-7 through 2-17 show general operational conditions for NMP2 in theMELLLA+ operating domain are well within expected parameters.
2.2 THERMAL LIMITS ASSESSMENT The effect of MELLLA+ on the MCPR safety and operating limits, maximum average planarlinear heat generation rate (MAPLHGR),
and LHGR limits is described below. As required byLimitation and Condition 9.6 of the Methods LTR SER, the GE14 fuel bundle R-factors generated for this project are consistent with GNF standard design practices, which use an axialvoid profile shape with 60% average in-channel voids. This is consistent with lattice axial voidconditions expected for the hot channel operating state as shown in Figure 2-18. As required byMethods LTR SER Limitation and Condition 9.15, the nodal void reactivity biases applied inTRACG are applicable to the lattices representative of fuel loaded in the core.The topics addressed in this evaluation are:2-3 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Topic M+LTR Disposition NMP2 ResultSafety Limit MCPR [[Operating Limit MCPRMAPLHGR LimitLHGR Limit ]]2.2.1 Safety Limit Minimum Critical Power RatioEr]] the SLMCPR is calculated based on the actual coreloading pattern for each reload core. In the event that the cycle-specific SLMCPR is notbounded by the current NMP2 TS value, NMP2 must implement a license amendment to changethe TS.[[ ]] the SLMCPR analysis for NMP2reflects the actual plant core loading pattern and is performed for each reload core. The cycle-specific SLMCPR will be determined using the methods defined in Reference
: 4. As required byM+LTR SER Limitation and Condition 12.6, the SLMCPR will be calculated at the ratedstatepoint (100% CLTP / 100% CF), the upper right comer of the MELLLA+ upper boundary(100% CLTP / 85% CF), the lower left comer of the MELLLA+ upper boundary (77.6% CLTP /55% CF), and the CLTP at the ICF statepoint (100% CLTP / 105% CF) (i.e., Figure 1-1Statepoints E, N, M, and F, respectively).
See Section 1.2.1 for further information on thepower-to-flow statepoints.
The currently approved off-rated CF uncertainty applied to the SLOoperation is used for the minimum CF Statepoint N and at 55.0% CF Statepoint M. Thecalculated values will be documented in the SRLR.As required by Methods LTR SER Limitation and Condition 9.5 and M+LTR SER Limitation and Condition 12.24.3, for MELLLA+ operation, a +0.02 adder will be added to thecycle-specific SLMCPR. The cycle-specific SLMCPR analysis will incorporate the +0.02 adderfor MELLLA+ operation.
The calculated values will be documented in the SRLR. A TS changewill be requested if the current value is not bounding.
2.2.2 Operating Limit Minimum Critical Power Ratio]] the OLMCPR is calculated by adding the change inMCPR due to the limiting AOO event to the SLMCPR. [[]] The OLMCPR is determined on a cycle-specific basis from2-4 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)the results of the reload transient
: analysis, as described in Reference
: 4. The cycle-specific analysisresults are documented in the SRLR and included in the COLR. The MELLLA+ operating conditions do not change the methods used to determine this limit.[[ ]] the OLMCPR for NMP2 iscalculated by adding the change in MCPR due to the limiting AOO event to the SLMCPR.]] if the Methods LTR SER and M+LTR SER penalties are ignored for NMP2. The OLMCPR for NMP2 is determined on a cycle-specific basis from theresults of the reload transient
: analysis, as described in Reference
: 4. The NMP2 cycle-specific analysis results are documented in the SRLR and included in the COLR. The MELLLA+operating conditions do not change the methods used to determine this limit. A +0.01 adder willbe applied to the resulting OLMCPR as required by Limitation and Condition 9.19 of theMethods LTR SER. In the event that the cycle-specific reload analysis is based on TRACGrather than ODYN for AOO, no 0.01 adder to the OLMCPR is required.
[[2.2.3 Maximum Average Planar Linear Heat Generation Rate Limits[R ]] MAPLHGR limitsensure that the plant does not exceed regulatory limits established in 10 CFR 50.46. Section 4.3,Emergency Core Cooling System Performance, presents the evaluation to demonstrate that plantsmeet the regulatory limits in the MELLLA+ operating domain. [[1]]Er ]] the NMP2 MAPLHGR limitsensure that NMP2 does not exceed regulatory limits established in 10 CFR 50.46. Section 4.3 ofthis M+SAR presents the evaluation to demonstrate that NMP2 meets the regulatory limits in theMELLLA+ operating domain. [[]] The MELLLA+ operating conditions do not change the methods used to determine this limit.[[2.2.4 Linear Heat Generation Rate LimitsEr ]] LHGR limits ensure thatthe plant does not exceed fuel thermal-mechanical (T-M) design limits. The LHGR isdetermined by the fuel rod T-M design and is not affected by MELLLA+ operating domainexpansion.
No changes to the fuel rod are required as a part of MELLLA+.
[[2-5 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)]] the NMP2 LHGR limits ensurethat the plant does not exceed fuel T-M design limits. There are no changes to the NMP2 fuel orfuel design limits as a result of MELLLA+.
NMP2 continues to use GEl4 fuel. [[]] The MELLLA+ operating conditions do not change the methods used to determine this limit.[[2.2.5 Power-to-Flow RatioMethods LTR SER Limitation and Condition 9.3 requires that plant-specific EPU and expandedoperating domain applications confirm that the core thermal power to CF ratio does not exceed50 MWt/Mlbm/hr at any statepoint in the allowed operating domain. For plants that exceed thepower-to-flow value of 50 MWt/Mlbmihr, the application will provide a power distribution assessment to establish that axial and nodal power distribution uncertainties determined vianeutronic methods have not increased.
The core thermal power to CF ratio at steady-state and off-rated conditions along the MELLLA+boundary is reported in Table 2-2.2.3 REACTIVITY CHARACTERISTICS The effect of MELLLA+ on hot excess reactivity, strong rod out (SRO) shutdown margin, andSLS shutdown margin is described below. The topics addressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultHot Excess Reactivity Strong Rod Out Shutdown MarginSLS Shutdown Margin2.3.1 Hot Excess Reactivity operation in the MELLLA+ operating domain may change the hot excess reactivity during thecycle. This change in reactivity does not affect safety and is not expected to significantly affectthe ability to manage power distribution through the cycle and to achieve the target power level.]] The MELLLA+ operating conditions do notchange the methods used to evaluate hot excess reactivity.
2-6 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)]] NMP2 continues to operate on a 24-month cycle. TheMELLLA+ operating conditions do not change the NMP2 methods used to evaluate thatsufficient hot excess reactivity exists to match the 24 -month cycle conditions.
2.3.2 Strong Rod Out Shutdown Marginhigher core average void fraction results in higher plutonium production, increased hot reactivity later in the operational cycle, and decreased hot-to-cold reactivity differences.
Smaller coldshutdown margins may result from cores designed for operation with the MELLLA+ operating domain expansion.
This potential loss in margin is offset through core design to maintain currentdesign and TS cold shutdown margin requirements.
All minimum SRO shutdown marginrequirements apply to cold most reactive conditions and are maintained without change forMELLLA+ implementation.
In order to account for reactivity uncertainties, including the effectsof temperature and analysis
: methods, margin well in excess of the TS limits is included in thedesign requirements.
[[The MELLLA+ operating conditions do not change the methods used to evaluate SRO shutdownmargin.[[I]] NMP2 current design and TS cold shutdown marginlimits are unchanged by MELLLA+.
The MELLLA+ operating conditions do not change theNMP2 methods used to evaluate that SRO shutdown margin meets the current NMP2 design andTS cold shutdown limits.2.3.3 SLS Shutdown Margin]] higher core average void fraction results in higher plutonium production, increased hot reactivity later in the operational cycle, and decreased hot-to-cold reactivity differences.
Smaller cold shutdown margins may result from cores designed for operation with the MELLLA+ operating domain expansion.
This potential loss in margin is offset throughcore design to maintain current design and SLS TS requirements.
All minimum SLS TSrequirements apply to most reactive SLS conditions and are maintained without change forMELLLA+ implementation.
In order to account for reactivity uncertainties, including the effectsof temperature and analysis
: methods, margin in excess of the TS limits is included in the design2-7 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)requirements.
[[]] The MELLLA+operating conditions do not change the methods used to evaluate the SLS shutdown margin.[[i]] NMP2 current design and SLS TS requirements for minimumnatural boron equivalent are unchanged by the SLS performance modification or MELLLA+.The MELLLA+ operating conditions do not change the NMP2 methods used to evaluate thatSLS shutdown margin meets the current NMP2 design and SLS TS requirements.
The SLSperformance modifications are to increase the boron injection rate to support ATWS evaluations and do not affect the SLS shutdown margin evaluation.
===2.4 STABILITY===
The DSS-CD stability solution (Reference
: 2) has been shown to provide an early trip signal uponinstability inception prior to any significant oscillation amplitude growth and MCPR degradation for both core-wide and regional mode oscillations.
NMP2 will implement the DSS-CD solutionconsistent with the M+LTR. DSS-CD implementation includes any limitations and conditions inthe DSS-CD SER (Reference 2). In accordance with DSS-CD LTR SER Limitation andCondition 5.1 (Reference 2), because NMP2 is implementing DSS-CD using the NRC approvedGEH Option III platform, a plant-specific review is not required.
There were no changesproposed in the bounding uncertainty or in the process to bound the uncertainty in the MCPR.Topic M+LTR Disposition NMP2 ResultDSS-CD Setpoints
[[Armed RegionBackup Stability Protection (BSP) ]]2.4.1 DSS-CD Setpoints
]] As a part of DSS-CD implementation, the applicability checklist is incorporated into the reload evaluation process and is documented in the SRLR.DSS-CD implementation also includes incorporation of appropriate
[[ ]] analysesto be performed if a specific reload analysis
[[]] DSS-CD is incorporated per the requirements of the DSS-CDLTR. This implementation requires that a process for reviewing the DSS-CD setpoints for eachreload analysis is in place. [[2-8 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)]] no further review of MELLLA+ isnecessary to evaluate the adequacy of the DSS-CD setpoints.
[[ ]] NMP2 will incorporate theDSS-CD solution consistent with the requirements of the DSS-CD LTR. Implementation ofDSS-CD in accordance with the DSS-CD LTR ensures that NMP2 incorporates the applicability checklist into the reload evaluation process and documents the results of the applicability checklist review in the SRLR. DSS-CD implementation per the DSS-CD LTR also ensures thatNMP2 incorporates appropriate
[[ ]] analyses to be performed if a specific reloadanalysis
[[The generic DSS-CD licensing basis applicable to NMP2 is documented in Section 4.7 ofReference
: 2. [[]] The step-by-step process summary for DSS-CD application of higher amplitude discriminator setpoint (SAD) is detailed in Table 4-17 of Reference
: 2. The results of theapplication of this process to NMP2 are summarized below.[[2-9 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)2-10 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)]]The CDA setpoint calculation formula and the adjustable parameter values are defined in theDSS-CD LTR (Reference 2). In accordance with DSS-CD LTR SER Limitation andCondition 5.2 (Reference 2), the DSS-CD LTR, or GESTAR II including the approved DSS-CDLTR, is referenced in the proposed TS changes for implementation of DSS-CD.2.4.2 Armed Region2-11 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)]]The generic boundaries of the armed region were approved as part of the DSS-CD LTR.[[]] no further review of MELLLA+ is necessary to evaluate the adequacyof the armed region.Erno further review of MELLLA+ is necessary to evaluate the adequacy of the armedregion.Er2.4.3 Backup Stability Protection Er ]] the DSS-CD LTRdefines the BSP along with a generic process for confirming that the BSP requirements are metin each reload analysis.
This BSP may be used when the OPRM system is temporarily inoperable.
Implementation of DSS-CD per the DSS-CD LTR requires that the alternate stability protection approach is confirmed on a cycle-specific basis to demonstrate adequacy for eachreload cycle. [[no further review of MELLLA+ is necessary to evaluatethe adequacy of the BSP.Er ]] NMP2 will incorporate theDSS-CD solution in accordance with the requirements of the DSS-CD LTR. Implementation ofDSS-CD in accordance with the DSS-CD LTR requires that NMP2 confirm the BSP approach isadequate as a part of the reload. [[]] no further review of BSP is required.
Er2-12 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)2-13 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)2.5 REACTIVITY CONTROLThe control rod drive (CRD) system controls core reactivity by positioning neutron absorbing control rods within the reactor and scram the reactor by rapidly inserting control rods into thecore. No change is made to the control rods or drive system due to MELLLA+.
The topicsaddressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultScram Time ResponseCRD Positioning and CoolingCRD Integrity 2.5.1 Control Rod Scram[ ]]forBWR/3, BWR/4, and BWR/5 plants the hydraulic control unit accumulators supply the initialscram pressure and, as the scram continues, the reactor becomes the primary source of pressureto complete the scram.]] the NMP2 hydraulic control unitaccumulators supply the initial scram pressure and, as the scram continues, the reactor becomesthe primary source of pressure to complete the scram. The NMP2 reactor dome pressure is1,035 psia (1,020 psig) and does not change as a result of MELLLA+ operating domainexpansion.
[[2.5.2 Control Rod Drive Positioning and Cooling[[I]] As a result ofMELLLA+,
there is no increase in temperature and [[]] Therefore, the CRD positioning and cooling functions are not affected byMELLLA+.[[ ]] for NMP2, the reactor coolanttemperature does not increase.
[[2-14 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)2.5.3 Control Rod Drive Integrity
[]] thepostulated abnormal operating conditions for the CRD design assume a failure of the CRDsystem pressure-regulating valve that applies the maximum pump discharge pressure to the CRDmechanism internal components.
This postulated abnormal pressure bounds the AmericanSociety of Mechanical Engineers (ASME) reactor overpressure limit. [[no further evaluation of CRD integrity is requiredas result of MELLLA+.ER ]] the NMP2 CRD mechanism hasbeen analyzed for an abnormal pressure operation (the application of the maximum CRD pumpdischarge pressure) that bounds the ASME RPV overpressure condition.
[[]] Also, as stated inSection 3.1.2, for the ASME RPV overpressure condition, the peak RPV bottom head pressure isunchanged and remains less than the limit of 1,375 psig. [[]] and no further evaluation of CRD integrity is required as result of MELLLA+.Er2.6 ADDITIONAL LIMITATIONS AND CONDITIONS RELATED TO REACTOR CORE AND FUELPERFORMANCE For that subset of limitations and conditions relating to Reactor Core and Fuel Design, which didnot fit conveniently into the organizational structure of the M+LTR, the required information ispresented here. The information is identified by either the M+LTR SER (Reference
: 1) limitation and condition or the Methods LTR SER (Reference
: 3) limitation and condition to which itrelates.2.6.1 TGBLA/PANAC VersionIn developing the NMP2 equilibrium core, the latest versions of TGBLA and PANAC were used.Refer to Table 1-1 for the latest revisions to TGBLA and PANAC. Cycle-specific analyses willinclude the most recent TGBLA and PANAC versions.
As required by Methods LTR SERLimitation and Condition 9.1, the most recent versions of TGBLA and PANAC are used.2.6.2 M+LTR SER Limitation and Condition 12.24.12-15 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)2.6.3 LHGR and Exposure Qualification Methods LTR SER Limitation and Condition 9.12 states that once the PRIME LTR(Reference
: 15) and its application are approved, future license applications for EPU andMELLLA+ referencing LTR NEDC-33173P-A must utilize the PRIME T-M methods.
ThePRIME LTR was approved on January 22, 2010 (Reference
: 15) and implemented in GESTAR IIin September 2010 (Reference 4). The NMP2 M+SAR has a PRIME T-M basis. PRIME fuelparameters have been used in all analyses requiring fuel performance parameters.
The T-M evaluation performed in support of the NMP2 M+SAR was performed using thePRIME T-M methodology.
2.6.4 GEXL-PLUS and Pressure Drop DatabaseThe applicability of the GE14 experimental GEXL-PLUS and pressure drop database isconfirmed for operation in the MELLLA+ domain.The Methods LTR NEDC-33173P-A (Reference
: 3) documents all analyses supporting theconclusions in this section that the application ranges of GEH codes and methods are adequate inthe MELLLA+ operating domain. In accordance with M+LTR SER Limitation andCondition 12.1, the range of mass fluxes and power/flow ratios in the GEXL database covers theintended MELLLA+ operating domain. The database includes low flow, high qualities, and voidfractions.
There are no restrictions on the application of the GEXL-PLUS correlation in theMELLLA+ operating domain.2-16 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Table 2-1 Peak Nodal Exposures Peak Nodal ExposurePlant Cycle (~IT(GWd/ST)A 18 38.849A 19 43.784B 9 56.359B 10 51.544C 7 53.447C 8 47.766D 13 56.660E 11 55.387F EQ- 120% 51.174NMP2 MELLLA+ 52.0032-17 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Table 2-2 Core Thermal Power to Core Flow Ratio at Steady-State andOff-Rated Conditions Operating Domain Core Thermal Power Core Flow Power-to-Flow RatioStatepoint*
(MWt / %EPU) (Mlbm/hr
/ %rated) (MWt/MlbmI/hr)
M/M+ Boundary "D" 3,988/100 107.4/99 37.13M+ Boundary "N" 3,988 / 100 92.2 / 85 43.24M+ Boundary "M" 3,095 / 77.6 59.7/55 51.86M/M+ Boundary "L" 2,727.8 / 68.4 59.7 / 55 45.71"*" Statepoints D, N, M, and L are shown in Figure 1-1.2-18 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Table 2-3 TLO and SLO DSS-CD Licensing Basis Generic Applicability EnvelopeChecklist Confirmation 2-19 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Table 2-4 [111Note: [[2-20 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Table 2-5 [111Note: [[2-21 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)8.07.5 '7 .0 -- ---- ----------'6.55.5--*-Plant A Cycle 18 m-Plant A Cycle 19 --.-Plant B Cycle 94.5 -o PlantBCyclelO 1 Plant C Cycle 7 --PlantCCydeB
-*-Plant D Cycle13 -PlantECyclell
-PlantF4.0, -*-NMP2 M ELLLA+0 2 4 6 8 10 12 14 16 18Cycle Exposure (GWDYST)Figure 2-1 Power of Peak Bundle versus Cycle Exposure2-22 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)1413~12E-6119)71-*-PlantA Cycle18 ---PlantA Cycle 19 -PlantB Cycle 9-4Plant B Cycle 10 -Plant C Cycle 7 -Plant C Cycle 8-PlantDCycle13
-PlantE Cycle 11 PPlantF-.--NM P2 M ELLLA+50 2 4 6 8 10 12Cycle Exposure (GWDIST)14 16 18Figure 2-2 Coolant Flow for Peak Bundle versus Cycle Exposure2-23 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)0.900.85W0.LL".0;0.75 -0.70-Plant A Cycle 18 --U- PlantA Cycle 19 &#xfd;-Plant B Cycle 9-Plant B Cycle 10 --PlantC Cycle 7 Plant C Cycle 8-Plant D Cycle 13 -PlantE Cycle 11 -Plant F--4-NMP2 MELLLA+I-0 2 4 6 8 10 12Cycle Exposure (GWDWS-)14 16 18Figure 2-3Exit Void Fraction for Peak Power Bundle versus Cycle Exposure2-24 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)0.900.85.X 0.85I-Lo.N0.750.70---Plant A Cycle 18-4Plant B Cycle 10--Plant D Cyclel3--NMP2 MELLLA+-u--Plant A Cycle 19-.--Plant C Cycle 7-Plant E Cycle 110 2 4 6 8 10 12Cycle Exposure (GWD/ST)14 16 18Figure 2-4Maximum Channel Exit Void Fraction versus Cycle Exposure2-25 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)t;L-49XUj=4)00,00.800.780.760.740.720.700.680.660.640.620.60--- -------- --------
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--PlantA Cycle 18---PlantB Cycle 10PlantD Cycle 13--NMP2 MELLLA+-4w- Plant A Cycle 19-o-Plant C Cycle 7-Plant E Cycle 110 2 4 6 8 10 12Cycle Exposure (GWDIST)14 16 18Figure 2-5 Core Average Exit Void Fraction versus Cycle Exposure2-26 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)161412,=I------------------------
------------
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-------------
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:4.2-* PlantA Cycle 18 -PlantA Cycle 19* lPlantBCycle10
-PlantC Cycle7-Plant D Cycle 13 -Plant C Cycle 11---NM P2 M ELLLA+---Plant B Cycle 9Plant C Cycle 8-Plant FL ]00 2 4 6 8 10 12Cycle Exposure (GWDP'ST) 14 16 18Figure 2-6 Peak LHGR versus Cycle Exposure2-27 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)ab lob go- U*Imon ----------
jW4=9 ! "FlM Fs f W2 3 , S , 1 1 , .t iQ 0 14Figure 2-7 Dimensionless Bundle Power at BOC (200 MWd/ST)2-28 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Sm -t~p~m -,no u-I"ab imI~,r-,TiNcoma POWILf-WRX" $
* 7 I S U 5 1U00d&#xb6; M T~Figure 2-8 Dimensionless Bundle Power at MOC (10,000 MWd/ST)2-29 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)@doWWWAPWcW00l2 46MSt0my Mof, i-j,o *as...4..
G ..I.. .; .!...Figure 2-9 Dimensionless Bundle Power at EOC (18,577 MWd/ST)2-30 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)mlllit,_= ' ., IDow-*-- Oft:--IKY _j 4 $
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s O F1: 1 17"Figure 2-10 Bundle Operating LHGR (kW/ft) at BOC (200 MWd/ST)2-31 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)go 1***0- toPcW _jtpu I'""'I*61
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-CLASS I (PUBLIC)F3os in Qfm -t6 NNm Sm rvzo" 2s P-0b.~ ~ ,Figure 2-12 Bundle Operating LHGR (kW/ft) at EOC (18,577 MWd/ST)2-33 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Ai';,'A-.'&#xfd;
! -' PRAI " ...j 2rub. oo, nm*rCTP 22comecwlow I [toit1Figure 2-13 Bundle Operating MCPR at BOC (200 MWd/ST)2-34 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)FOO F- Fof :,_. -.FrLWAG(.00"i 2sFnnMT Vcow1I 2 ) 4 I.
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-CLASS I (PUBLIC)"eine mmoCAIJT09'4.. ... ...... .. V'QolwmIM21*1I 2 s 4 s
* 7 1 0 S z 1 1 4 isFigure 2-15 Bundle Operating MCPR at EOC (18,577 MWd/ST)2-36 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)I AVAIXIU&#xfd;'
I I'.' FqrF___ mPcTV _- 4 As-L"u 'Il FEW mFKfur'izmm m ,Fo--n*m-,-F-m-F mi 2 B O4W 1E00 WMM1 3 S 4 6 I S I I U It 12 is 14 IFigure 2-16 Bundle Operating LHGR (kW/ft) at 15,000 MWdIST (Peak MFLPD Point)2-37 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)[ AFAIA-11,'
I I'.' pqr__&#xfd; F3OR1- m 1d094"how I 2 9S13FA:_1IViFigure 2-17 Bundle Operating MCPR at 1,500 MWd/ST (Peak MFLCPR Point)2-38 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)viil a11w l Ilio1111so IIUIII~3E~ruU~I*IhhIII~~huIIUIflhIIII~u~lhEIUI~t2
-c ZItef 1111111ol 1111f:fi9sl vies 1:a411 u4 olil UipolFigure 2-18 Bundle Average Void History for Bundles with Low CPRs2-39 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Core Flow (Mlbm/hr) 0 10 20 30 40 50 60 70 80 90 100 110 120130120110100908070600 50403020100OPRM Armed Region------ .. ... --------.....
The OPRM Armed Region is* defined by 75% drive flow. ."However the use of 75% coreflow is conservaive
.450040003500300025002000150010005000T.. 7-__0 10 20 30 40 50 60 70 80 90 100 110Core Flow (%)120Figure 2-19 Required OPRM Armed Region2-40 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)3.0 REACTOR COOLANT AND CONNECTED SYSTEMSThis section addresses the evaluations that are applicable to MELLLA+.3.1 NUCLEAR SYSTEM PRESSURE RELIEF AND OVERPRESSURE PROTECTION The topics addressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultFlow-Induced Vibration i[Overpressure Relief Capacity3.1.1 Flow-Induced Vibration because there is no increase in the maximum main steam (MS) line flow for the MELLLA+operating domain expansion, there is no effect on the flow-induced vibration (FIV) of the pipingand SRVs during normal operation.
[[]] for NMP2, maximum MS line(MSL) flow in the MELLLA+ operating domain does not increase.
The numerical valuesshowing no increase in maximum steam flow rate are presented in Table 1-2. MELLLA+ doesnot result in any increase to the NMP2 maximum MSL flow, and there is no effect on the FIVexperienced by the SRVs or piping during normal operation.
[[I]3.1.2 Overpressure Relief CapacityThe pressure relief system prevents overpressurization of the nuclear system during AOOs, theplant ASME upset overpressure protection event, and postulated ATWS events. The SRVsalong with other functions provide this protection.
For NMP2, the limiting overpressure event isthe main steam isolation valve closure with scram on high flux (MSIVF) event. The peak RPVbottom head pressure is unchanged and remains less than the ASME limit of 1,375 psig.The SRV setpoint tolerance is independent of the MELLLA+ operating domain expansion.
TheAOO, ASME overpressure, and ATWS response evaluations for MELLLA+ are performed usingexisting NMP2 SRV setpoint tolerances.
The SRV setpoint tolerances are monitored at NMP2for compliance to the TS requirements.
]] Thereare no changes made to the NMP2 licensing basis for the ASME overpressure event.]] The SRV tolerance assumed in the NMP2 ASME overpressure event3-1 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)analysis is 3%. The tolerance is consistent with the actual SRV performance testing conducted on the NMP2 SRVs per TS Surveillance Requirement 3.4.4.1.Er]] There are no changes to theexisting licensing basis assumptions and code inputs used for the NMP2 ASME overpressure event analysis.
The ASME overpressure analysis for NMP2 was performed at the 105% ICF core flowstatepoint, and at the 85% minimum CF statepoint using an approximate MELLLA+ equilibrium core. The analysis of the limiting overpressure event for NMP2 demonstrates that no change inoverpressure relief capacity is required.
[[]] This process is unchanged by MELLLA+.3.2 REACTOR VESSELThe RPV structure and support components form a pressure boundary to contain reactor coolantand form a boundary against leakage of radioactive materials into the drywell (DW). The topicsaddressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultFracture Toughness Reactor Vessel Structural Evaluation 3.2.1 Fracture Toughness The MELLLA+ operating domain expansion results in a slightly higher operating neutron flux inthe upper portion of the core due to decreased water density.
The effect of this water densityreduction is [[ ]] in peak vessel and peak shroud flux. Inaccordance with M+LTR SER Limitation and Condition 12.8, the MELLLA+ flux is calculated using the GEH flux evaluation methodology contained in NEDC-32983P-A (Reference 16),which is consistent with Regulatory Guide (RG) 1.190 (Reference
: 17) and was approved by theNRC in November 2005. The evaluation is based on an idealized equilibrium core loadingwhich is not a bounding core design. This core loading is intended to show general trends for thepurpose of comparison and demonstrating the anticipated effect on flux and fluence.
The NMP2RG 1.190 (Reference
: 17) fluence program monitors actual core operations to determine theeffect on fracture toughness.
The MELLLA+ operating domain flux distribution is assumed tobe similar to that of current licensed operating domain flux distribution, whereas the magnitude of flux level is proportional to the thermal power. The change to the NMP2 54 effective fullpower years (EFPYs) vessel internal diameter (ID) peak fluence as a result of implementing MELLLA+ is [[ 1]Key flux/fluence comparisons at 120% OLTP are provided in Table 3-1.Because there is no change to the NMP2 54 EFPY Vessel ID peak fluence as a result ofMELLLA+,
there is no change to the beltline adjusted reference temperature (ART). The3-2 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)pressure/temperature curves do not require revision as a result of MELLLA+ operating domainexpansion.
Because there is no change to the NMP2 54 EFPY Vessel ID peak fluence as a result ofMELLLA+,
there is no change to the upper shelf energy (USE). NMP2 continues to meet the50 ft-lb requirement in 10 CFR 50, Appendix GBecause there is no change to the NMP2 54 EFPY Vessel ID peak fluence as a result ofMELLLA+,
there is no change to the Weld Inspection Relief criteria for circumferential welds.Therefore, the inspection relief request does not require revision as a result of MELLLA+operating domain expansion.
As a result of MELLLA+ there is no change in the NMP2 54 EFPY Vessel ID peak fluence.Therefore, there are no changes to the NMP2 ART, USE, or Weld inspection relief values as aresult of MELLLA+.3.2.2 Reactor Vessel Structural Evaluation
[[]] there are no changes in the reactor operating
: pressure, FW flow rate, or steamflow rates for the MELLLA+ operating domain expansion.
Other applicable mechanical loadsdo not increase for the MELLLA+ operating domain expansion.
[[]] there is no change in the stress or fatigue for thereactor vessel components as a result of MELLLA+,
and no further evaluation is required.
[[ ]] for NMP2, there are no increases in the reactor operating
: pressure, or maximum steam or FW flow rates for the MELLLA+operating domain expansion.
The numerical values showing no increases in reactor operating
: pressure, or maximum steam or FW flow rates are presented in Table 1-2. Other NMP2mechanical loads do not increase as a result of the MELLLA+ operating domain expansion.
Therefore, there is no change in the stress and fatigue for the NMP2 reactor vessel components, and no further evaluation of NMP2 reactor vessel structural integrity is required.
3.3 REACTOR INTERNALS 3.3.1 Reactor Internal Pressure Differences The reactor internals include core support structure and non-core support structure components.
The topics addressed in this evaluation are:3-3 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)M+LTRTopic Disposition NMP2 ResultFuel Assembly and Control Rod Guide Tube Lift Forces [[Reactor Internal Pressure Differences for Normal, Upset,Emergency and Faulted Conditions Reactor Internal Pressure Differences (Acoustic andFlow-Induced Loads) for Faulted Conditions Reactor Internals Structural Evaluation for Normal,Upset, and Emergency Conditions Reactor Internals Structural Evaluation for FaultedConditions Steam Dryer Separator Performance Steam Line Moisture Performance Specification
]]3.3.1.1 Fuel Assembly and Control Rod Guide Tube Lift Forces]] fuel assembly and CRGT lift forces are calculated for normal, upset, emergency, and faulted conditions consistent with the existing plant designbasis. There are no increases in the core exit steam flow, reactor operating
: pressure, FW orsteam flow rates for the MELLLA+ operating domain expansion.
Because none of the preceding values change, the only remaining variable affecting the forces on the fuel assemblies andCRGTs for the normal, upset, emergency and faulted conditions in the MELLLA+ operating domain is the CF. Maximum CF is reduced in the MELLLA+ operating domain. [[]] Therefore, no further evaluation of fuel assembly or CRGT lift forces isrequired.
[[ ]] for NMP2, the difference betweenthe 100% CLTP / 105% core flow ICF operation point core exit steam flow and the 100% CLTP/ 85% core flow MELLLA+ operation point core exit steam flow is essentially unchanged (lessthan a 0.4% increase).
The differences between the vessel steam flow and FW flow rates for thetwo power-flow points are essentially unchanged, as well (both less than a 0.2% decrease).
Thedome pressures for the two power-flow points are identical.
The small differences between thecore exit steam flows, vessel steam flows and FW flow rates have a negligible effect on the fuelassembly and CRGT lift forces calculated for normal, upset, emergency and faulted conditions.
Therefore, because the NMP2 CF at the MELLLA+ statepoint at 85% CF is less than the currentlicensed operating domain statepoint at 105% CF, the normal, upset, emergency and faulted fuelassembly and CRGT lift forces for the MELLLA+ operating domain [[3-4 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)]] and no further evaluation of these forces is required.
I]3.3.1.2 Reactor Internal Pressure Differences for Normal, Upset, Emergency and FaultedConditions
[[]] RIPDs (pressure differentials across the components) arecalculated for normal, upset, emergency and faulted conditions consistent with the existing plantdesign basis. There are essentially no changes in the core exit steam flow, reactor operating
: pressure, FW or steam flow rates for the MELLLA+ operating domain expansion.
Because noneof the preceding values change, the only remaining variable affecting the RIPDs for the normal,upset, emergency and faulted conditions in the MELLLA+ operating domain is the CF.Maximum CF is reduced in the MELLLA+ operating domain. [[]] Therefore, no further evaluation of RIPDs for normal,upset, emergency and faulted conditions is required.
[[ ]] for NMP2, the difference betweenthe 100% CLTP / 105% core flow ICF operation point core exit steam flow and the 100% CLTP/ 85% core flow MELLLA+ operation point core exit steam flow is less than a 0.4% increase.
The differences between the vessel steam flow and FW flow rates for the two power-flow pointsare both less than a 0.2% decrease.
The dome pressures for the two power-flow points areidentical.
The small differences between the core exit steam flows, vessel steam flows and FWflow rates have a negligible effect on the RIPDs for normal, upset, emergency and faultedconditions.
Therefore, because the NMP2 CF at the MELLLA+ statepoint at 85% CF is lessthan the current licensed operating domain statepoint at 105% CF, the normal, upset, emergency and faulted condition RIPDs for the MELLLA+ operating domain [[]] which includes ICF up to 105% RCF.]] and no further evaluation of thesepressure differentials is required for normal, upset, emergency and faulted conditions.
3.3.1.3 Reactor Internal Pressure Differences (Acoustic and Flow-Induced Loads) forFaulted Conditions As part of the RIPDs, the faulted acoustic and flow induced loads in the RPV annulus on jetpump, core shroud and core shroud support resulting from the recirculation line break LOCAhave been considered in the NMP2 evaluation.
[[3-5 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)]] and NMP2 R[PDs for faulted conditions continueto be acceptable.
[[3.3.2 Reactor Internals Structural Evaluation Structural integrity evaluations for MELLLA+ operating domain expansion are performed consistent with the existing design basis of the components.
[[]] Therefore, no further structural evaluation of the reactor internals isrequired.
An evaluation of the load categories applicable to the reactor internals under normal,upset, and emergency conditions is presented below:MELLLA+ ResultsLoad Category for Normal, Upset and Emergency Conditions Dead WeightSeismic (Operating BasisEarthquake (OBE))RIPDsFuel Assembly and CRGT LiftForcesContainment Dynamic Loads -(LOCA and SRV)Fuel Lift LoadsThermal Effects3-6 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)MELLLA+ ResultsLoad Category for Normal, Upset and Emergency Conditions Flow[[3.3.2.1 Reactor Internals Structural Evaluation for Faulted Conditions
]] The M+LTRalso defines that if the load conditions do not increase in the MELLLA+ operating domain, thenthe existing analysis results are bounding and no further evaluation is required.
Applicable loads, load combinations, and service conditions are evaluated consistent with the plant designbasis for each component.
As shown below, [[]] and thus no further evaluation is required.
MELLLA+ ResultsLoad Category for Faulted Conditions Dead WeightSeismic (Safe ShutdownEarthquake (SSE))RIPDsFuel Assembly and CRGT LiftForcesContainment Dynamic Loads -(LOCA and SRV)Annulus Pressurization Jet ReactionFuel Lift LoadsFlowAcoustic and Flow-Induced LoadsDue To Recirculation Line Break3-7 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)The faulted condition loads for the NMP2 reactor internal components resulting from theMELLLA+ operating domain conditions
[[1] no further evaluation for Reactor Internals Structural Evaluation for faulted conditions is required.
3.3.3 Steam Separator and Dryer Performance The performance of the NMP2 steam separator-dryer has been evaluated to determine themoisture content of the steam leaving the RPV. Compared to the current licensed operating domain (100% CF statepoint),
the average separator inlet flow decreases and the averageseparator inlet quality increases at MELLLA+ conditions.
These factors, in addition to the coreradial power distribution, affect the steam separator-dryer performance.
Steam separator-dryer performance was evaluated at equilibrium cycle limiting conditions of high radial power peakingand 85% RCF to assess their capability to provide the quality of steam necessary to meetoperational criteria at MELLLA+ operating conditions.
The evaluation of steam separator and dryer performance indicates that MCO increases atMELLLA+ conditions.
This increase resulted in a MCO value above the original moistureperformance specification of 0.10 wt.%. Section 3.3.4 identifies a plant-specific moistureperformance specification based on as installed hardware.
3.3.4 Steam Line Moisture Performance Specification The effect of increased MCO on plant operation has been analyzed to verify acceptable steamseparator-dryer performance under MELLLA+ operating conditions for a maximum moisturecontent of 0.25 wt.%. MCO is monitored during operation to ensure adequate operating limitations are implemented as required to maintain MCO within analyzed conditions.
Theamount of time NMP2 is operated with higher than the original design moisture content(0.10 wt.%) is minimized by operations.
MCO monitoring periodicity is based upon results ofstartup testing, operating experience, control rod pattern and time in core life.The ability of the steam dryer and separator to perform their design functions during MELLLA+operation was evaluated.
The NMP2 plant-specific evaluation concluded that the performance ofthe steam dryer and separator remains acceptable and the dryer skirt remains covered at L4, thelow water level alarm in the MELLLA+ region.MELLLA+ operation decreases the CF rate, resulting in an increase in separator inlet quality forconstant reactor thermal power. These factors, in addition to core radial power distribution, influence steam separator-dryer performance.
NMP2's steam separator/dryer performance wasevaluated on a plant-specific basis to determine the influence of MELLLA+ on the steam dryerand separator operating conditions:
(1) the entrained steam (i.e., carryunder) in the waterreturning from the separators to the reactor annulus region; (2) the moisture content in the steamleaving the RPV into the MSLs; and (3) the margin to dryer skirt uncovery.
3-8 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)The moisture content of the steam leaving the RPV increases in the MELLLA+ domain. Theeffect of the increase has been analyzed in the tasks that use the MCO value from Sections 3.3.3and 3.3.4. The effects of increased moisture are discussed in the following sections:
: a. 3.5.1 Reactor Coolant Pressure Boundary Piping[R 1] as discussed inSection 3.3.3, the MCO may increase during the cycle when a plant is operating at ornear the MELLLA+ minimum CF rate.R[ ]] the MCO for NMP2 may increase to amaximum of 0.25 wt.% during the cycle when NMP2 is operating at or near theMELLLA+ minimum CF rate.b. 8.1 Liquid and Solid Waste Management Although the volume of waste generated is not expected to increase, potentially higherMCO in the reactor steam would result in a slightly higher loading on the condensate demineralizers.
Because the higher moisture content will occur infrequently, theMELLLA+ operating domain expansion will not cause the condensate demineralizer backwash frequency to be changed significantly as discussed in Section 8.1.2. Thereactor water cleanup (RWCU) filter demineralizer backwash frequency is not affectedbecause there is no effect on RWCU inlet conditions for MELLLA+,
as discussed inSection 3.11.c. 8.4.2 Fission and Activation Corrosion ProductsSteam separator and dryer performance for MELLLA+ operation is discussed inSection 3.3.3. The moisture content of the MS leaving the vessel may increase up to0.25 wt.% at times while operating near the minimum CF in the MELLLA+ operating domain. The distribution of the fission and activated corrosion product activity betweenthe reactor water and steam is affected by the increased moisture content.
With increased MCO, additional activity is carried over from the reactor water with the steam. Themaximum allowable moisture content leaving the reactor vessel is 0.25 wt.%.d. 8.5 Radiation LevelsAs discussed in Section 8.4, the moisture content of the MS leaving the vessel mayincrease at certain times while operating in the MELLLA+ operating domain. However,the NMP2 MCO will be monitored and controlled to < 0.25 wt.%, which is within theanalytical assumption of 0.35 wt.% used in the determination of normal operation radiation levels. The overall radiological effect of the increased moisture content is afunction of the plant water radiochemistry and the levels of activated corrosion productsmaintained.
: e. 10.7.2 Flow Accelerated Corrosion The EPU flow accelerated corrosion (FAC) evaluation for MS and extraction steampiping assumed a 0.25 wt.% MCO for mechanical thermal conditions.
This 0.25 wt.%3-9 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)MCO value bounds the maximum predicted MCO value of 0.236 wt.% for MELLLA+based on equilibrium fuel cycle burnup assumptions.
The predicted MCO is a function offuel loading and rod patterns throughout the burnup history.
The MSIVs allowable moisture content was found to be acceptable for MELLLA+ operation based on GEHengineering
: judgment, operating experience, and NMP2's MSIV inspection/maintenance program.
The increased moisture content will not create a significant change in wear onMS piping and components based on the evaluations performed using CHECWORKSTM and design assessments for the components.
MCO will be managed with monitoring toidentify and track the duration of MCO above 0.1 wt.% based on taking chemicalsamples once per month. The FAC monitoring program was reviewed for potential changes to the program.
No changes to the FAC program are required.
The FAC relatedpiping and component wear is managed by the FAC program and Maintenance Rule asdiscussed in Section 10.7.2.f. 5.2.4 Main Steam Flow -FW Flow MismatchOperation at the higher MCO performance specification is acceptable.
With a dryermoisture performance specification up to 0.35 wt.%, the additional coolant removed fromthe RPV must be returned to the reactor in order to maintain correct water level. The FWsystem may be required to provide a slightly higher flow rate. The effect of the increased MSL MCO is to cause a slight imbalance in the FW control system control point. With aplant bias of 0.48 inches per percent this translates to z 0.12 inches of bias in the waterlevel.g 3.4.1 Piping Components with Flow-Induced Vibration
-Safety RelatedAdequate margin exists to the FIV of the sample probes and thermowells due to the largemargin available in the design.3.4 FLOW-INDUCED VIBRATION The FIV evaluation addresses the influence of the MELLLA+ operating domain expansion onreactor coolant pressure boundary (RCPB) piping, RCPB piping components, and RPV internals.
The topics addressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultPiping FIV Evaluation Recirculation System PipingMain Steam PipingFeedwater PipingSafety-Related Thermowells and ProbesRPV Internals FIV Evaluation 3.4.1 FIV Influence on Piping]] Flow rates in the recirculation system3-10 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)piping, MS piping, and FW piping as well as associated MS and FW branch lines do not increaseas a result of MELLLA+ operating domain expansion.
[[]] and no further evaluation of FIV influence on recirculation, MS,and FW piping is required.
]] For NMP2, there are noincreases in the recirculation system, MS, or FW flow rates as a result of MELLLA+ operating domain expansion as compared to the current licensed operating domain. The numerical valuesshowing no increases in recirculation system, MS, or FW flow rates are presented in Table 1-2.]] and no further evaluation ofFIV influence on recirculation, MS, and FW piping is required.
]] Because the flow rates inthese piping systems do not increase for MELLLA+,
there is no increase in FIV for the safety-related thermowells and probes. [[]] and no further evaluation of FIV influence on safety-related thermowells and probes is required.
Also, []] For NMP2, there is no increase in flowin these systems for MELLLA+.
Therefore, there is no increase in FIV for the safety-related thermowells and probes. [[]] and no further evaluation of FIVinfluence on safety-related thermowells and probes is required.
[[3.4.2 FIV Influence on Reactor Internals Er]] evaluates the effect of theMELLLA+ operating domain expansion on the following components:
shroud, shroud head andsteam separator-dryer, core spray (CS) line, low pressure coolant injection (LPCI) coupling, CRGT, in-core guide tubes, fuel channel, LPRM / intermediate range monitor (IRM) tubes, jetpumps, jet pump sensing lines (JPSLs),
and FW sparger.
The MELLLA+ operating domainexpansion results in decreased core and recirculation flow as well as no increase in the MS and3-11 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)FW flow rates. [[]] the effect of the MELLLA+operating domain expansion is presented for the following components:
Component(s)
MELLLA+ ResultsShroudShroud Head and SteamSeparator-Dryer CS LineLPCI CouplingCRGTIn-Core Guide TubesFuel ChannelLPRM/IRM TubesJet PumpsJPSLsFW SpargerFor NMP2, the MELLLA+ operating domain expansion results in decreased core andrecirculation flow as well as no increase in the MS and FW flow rates. The numerical valuesshowing a decrease in core and recirculation flow as well as no increase in maximum steam orFW flow rates are presented in Table 1-2. As presented in the table above, [[]] The reduced CF and recirculation flow3-12 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)in the MELLLA+ domain [[]] Therefore, no further evaluation of the FIV influence on reactor internals isrequired for the NMP2 MELLLA+ operating domain expansion.
Er3.5 PIPING EVALUATION 3.5.1 Reactor Coolant Pressure Boundary PipingThe RCPB piping systems evaluation consists of a number of safety-related piping subsystems that move fluid through the reactor and other safety systems.
The topics addressed in thisevaluation are:Topic M+LTR Disposition NMP2 ResultMain Steam and Feedwater (Inside Containment)
Recirculation and Control Rod DriveReactor Core Isolation Cooling (RCIC)High Pressure Core Spray (HPCS)RWCULow Pressure Core Spray (LPCS)Standby Liquid ControlResidual Heat Removal (RHR)RPV Head Vent LineSRV Discharge Line (SRVDL)Safety-Related Thermowells The piping systems are required to comply with the structural requirements and Pressure Vessel (BPV) Code (or an equivalent Code) applicable at theor the governing code used in the stress analysis for a modified component.
of the ASME Boilertime of construction 3.5.1.1 Main Steam and Feedwater Piping Inside Containment Er]] the system temperatures, pressures, and flows in the MELLLA+operating domain are within the range of rated operating parameters for the MS and FW pipingsystem (inside containment).
[[1]the temperatures, pressures, and flows in MS and FW systems for MELLLA+ operation are3-13 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)within the range of rated operating parameters for those systems, no further evaluation isrequired related to RCPB piping for MS and FW piping inside containment.
[[ ]] for NMP2, the MS and connected branch piping (i.e., RCIC steam lines) and FW temperatures, pressures, and flows are within therated operating parameters for the MS and FW systems.
MS and FW temperatures, flows, andpressures at MELLLA+ conditions are bounded by the EPU temperatures, flows, and pressures, and as such are within the design values used in the design of the piping and supports chosen forworst case conditions.
NMP2 MS and FW piping inside containment is designed in accordance with the original code of record, ASME BPV Code, Section III, Subsection NB, 1974 Edition.[[]] the temperatures, pressures, and flows in NMP2 MS and FWsystems for MELLLA+ operation are within the range of rated operating parameters for thosesystems, and no further evaluation is required related to the NMP2 RCPB piping for MS and FWinside containment.
[I ]] as discussed in Section 3.3.3,the MCO may increase during the cycle when a plant is operating at or near the MELLLA+minimum CF rate. The generic disposition concludes that the change in erosion/corrosion ratesas a result of increased carryover is adequately managed by the existing programs discussed inSection 10.7.2.Er ]], the MCO for NMP2 may increase to a maximumof 0.25 wt.% during the cycle when NMP2 is operating at or near the MELLLA+ minimum CFrate. NMP2 implements programs adequate to manage this change in the erosion/corrosion rateas described in Section 10.7.2.The effect of MELLLA+ on the EPU AP load SC 09-01 evaluation has determined that theamplified response spectra (ARS) remains conservative for the rated power MELLLA+ Point N(Figure 1-1). The off-rated SC 09-01 methods show minor shifts in the ARS for selected nodes(power-flow map Points A and N in Figure 1-1) as compared to the EPU bounding spectrum.
The review of the EPU SC 09-01 AP load assessments show the minor shifts represent aninsignificant change in the total load combination for these piping systems such that theconclusions reached for the EPU assessment remain unchanged.
3.5.1.2 Reactor Recirculation and Control Rod Drive Systems]] there is no change in the maximum operating systemtemperatures, pressures, and flows in the MELLLA+ operating domain for the recirculation piping system and attached RHR piping system. [[3-14 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)]] no further evaluation of the RCPB piping -reactor recirculation and CRDsystems is required for MELLLA+ operating domain expansion.
[[ ]] for NMP2, the reactorrecirculation and CRD system temperatures, flows, and pressures at MELLLA+ conditions arebounded by the EPU temperatures, flows, and pressures, and as such are within the design valuesused in the design of the piping and supports chosen for worst case conditions.
3.5.1.3 Other RCPB Piping Systems3.5.1.3.1 Other RCPB Piping Systems -HPCS, LPCS, RHR/LPCI, and SLS]] Because the piping systems meeting the criteria
[[]] their susceptibility toerosion/corrosion does not increase, and no further evaluation of these other RCPB pipingsystems is required.
[[ ]] MELLLA+ operating domainexpansion for NMP2 does not change the maximum operating temperature,
: pressure, or flow rateof any of the following systems:
HPCS, LPCS, RHR/LPCI, and SLS.HPCS, LPCS, RHR/LPCI, and SLS temperatures, flows, and pressures at MELLLA+ conditions are bounded by the EPU temperatures, flows, and pressures, and as such are within the designvalues used in the design of the piping and supports chosen for worst case conditions.
Each of these NMP2 systems [[]] their susceptibility toerosion/corrosion does not increase, and no further evaluation of these other RCPB pipingsystems is required for NMP2.3.5.1.3.2 Other RCPB Piping Systems -RPV Head Vent Line and SRV Discharge Lines[[3-15 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)]] For the RPV head vent line and theSRVDL, there is no change in the temperature,
: pressure, or flows in these systems as a result ofMELLLA+ operating domain expansion.
Because the piping systems have no change in systemtemperature, pressure or flow as a result of MELLLA+ operating domain expansion,
[[]] Their susceptibility to erosion/corrosion does not increase, andno further evaluation of these other RCPB piping systems is required.
[[ ]] MELLLA+ operating domainexpansion for NMP2 does not change the maximum operating temperature,
: pressure, or flow rateof any of the following piping systems:
RPV head vent line and SRVDL.RPV head vent line and SRVDL temperatures, flows, and pressures at MELLLA+ conditions arebounded by the EPU temperatures, flows, and pressures, and as such are within the design valuesused in the design of the piping and supports chosen for worst case conditions.
Additionally, there is no flow through the SRVDL during normal operating conditions.
The RPV head vent line and the SRVDL are unaffected by MELLLA+ operating domainexpansion.
[[ ]] their susceptibility to erosion/corrosion does not increase, and no further evaluation of these other RCPB piping systems is required forNMP2.3.5.1.3.3 Other RCPB Piping Systems -RWCU[[]] Because the RWCU system has no change insystem temperature, pressure or flow as a result of MELLLA+ operating domain expansion,
[[]] RWCU system susceptibility to erosion/corrosion does notincrease, and no further evaluation of the RWCU system is required.
Er ]] MELLLA+ operating domainexpansion for NMP2 does not change the maximum operating temperature,
: pressure, or flow rateof the RWCU system. RWCU system temperatures, flows, and pressures at MELLLA+conditions are bounded by the EPU temperatures, flows, and pressures, and as such are withinthe design values used in the design of the piping and supports chosen for worst case conditions.
The NMP2 RWCU system is unaffected by MELLLA+ operating domain expansion.
Er ]] the RWCU system susceptibility toerosion/corrosion does not increase, and no further evaluation of the RWCU system is required.
3.5.1.3.4 Other RCPB Piping Systems -Safety-Related Thermowells
[[]] Because the RCPB pipingsystems evaluated for EPU do not experience any increase in pressure, temperature, or flow atMELLLA+,
their susceptibility to erosion/corrosion does not increase, and no further evaluation of safety-related thermowells is required for NMP2.3-16 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)]] the NMP2 safety-related thermowells are unaffected by MELLLA+ as the evaluations performed for the currently licensed operating domain are bounding for MELLLA+ conditions.
[[Their susceptibility to erosion/corrosion does not increase and no further evaluation of safety-related thermowells is required for NMP2.Because all of the piping systems in Section 3.5.1.3 meet the criteria listed [[]] their susceptibility toerosion/corrosion does not increase, and no further evaluation of these other RCPB pipingsystems is required.
3.5.1.4 Other than Category "A" RCPB MaterialAs required by M+LTR SER Limitation and Condition 12.9, the following discussion ispresented regarding other than Category "A" materials that exist in the RCPB piping.Category "A" is assumed to mean intergranular stress corrosion cracking (IGSCC) Category "A"that is a resistant material to IGSCC for BWR piping weldments in accordance with GenericLetter (GL) 88-01 (Reference 18). Other than Category "A" is assumed to mean non-resistant orcracked materials for IGSCC BWR piping weldments in accordance with GL 88-01 (IGSCCCategories B through G). USAR Section 5.2-5 is only a general RCPB list and is not specifically related to IGSCC. The SER for GL 88-01, along with the associated technical evaluation, establishes the IGSCC categories and initial IGSCC related bases. The current IGSCC programis located within the in-service inspection (ISI) program plan (CNG-NMP2-ISI-003).
CNG-NMP2-ISI-003, Section 6.1 specifically identifies 49 welds that are in the IGSCC otherthan Category "A" (Categories D and E shown in Tables 6-1 and 6-2 and summarized inTable 6-5 and Appendix E). CNG-NMP2-ISI-003-10 shows the implementation schedule andhas the "ASME Section XI Category Item No." column as either "GLD" or "GL-E," whichidentifies the location of the weld.The NMP2 ISI program for all ASME Code Class 1 and 2 RCPB piping is in accordance with anNRC staff approved alternate risk-informed inspection program utilizing the NRC approvedElectric Power Research Institute (EPRI) methodology, Technical Report TR-1 12657,Revision B-A (Reference 19). In addition to the ASME Code, Section XI and the alternate risk-informed
: programs, NMP2 implements an augmented IGSCC inspection program in accordance with GL 88-01 (Reference 18), NUREG-0313 (Reference 20), and as modified by Boiling WaterReactor Vessel and Internals Project (BWRVIP)-75 (Reference
: 21) for IGSCC Category D weldexamination frequency using normal water chemistry.
NMP2 implements ASME Section XI,Appendix VIII for the performance demonstration for ultrasonic examination systemsadministrated through the EPRI performance demonstration initiative (PDI) program.Appendix VIII provided the requirements for the performance demonstration for ultrasonic examination procedures, equipment, and personnel to detect and size flaws. All of the above3-17 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)programs have been credited as an aging management program during the NMP2 license renewalprocess.Continued implementation of the current program ensures the prompt identification of anydegradation of RCPB components experienced during MELLLA+ operating conditions.
[[ ]] confirms that the augmented inspection programat NMP2 is adequate to address concerns related to other than Category "A" materials in theRCPB.3.5.2 Balance-of-Plant PipingThe BOP piping evaluation consists of a number of piping subsystems that move fluid throughsystems outside the RCPB. The topics considered in this section are:Topic M+LTR Disposition NMP2 ResultMain Steam and Feedwater (Outside Containment)
Reactor Core Isolation CoolingHigh Pressure Core SprayLow Pressure Core SprayResidual Heat RemovalHigh Pressure Coolant Injection (HPCI)Offgas SystemContainment Air Monitoring Neutron Monitoring System3.5.2.1 Main Steam and Feedwater (Outside Containment)
[[]] for all MS and FW piping systems, including the associated branch piping, thetemperature,
: pressure, flow, and mechanical loads do not increase due to the MELLLA+operating domain expansion.
[[]] The susceptibility of these piping systemsto erosion/corrosion increases only for the MS piping; however, that erosion/corrosion will beadequately managed as discussed in Sections 3.5.1.1 and 10.7.2. [[no further evaluation is required for BOP Piping -MS and FW(outside containment).
[ MELLLA+ operating domainexpansion for NMP2 does not change (no increase) the maximum operating temperature,
: pressure, flow rate, or mechanical loads for the MS and FW piping outside containment.
MS andFW system temperatures, flows, and pressures at MELLLA+ conditions are bounded by the EPUtemperatures, flows, and pressures, and as such are within the design values used in the design of3-18 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)the piping and supports chosen for worst case conditions.
The NMP2 MS and FW piping outsidecontainment is unaffected by the MELLLA+ operating domain expansion.
The NMP2 BOPpiping outside containment was typically designed in accordance with American NationalStandards Institute (ANSI) B331.1 (Reference
: 22) and as such, there were no fatigue analysesrequired or performed.
[[]], theFW piping outside containment susceptibility to erosion/corrosion does not increase, and nofurther evaluation is required.
The MS outside containment susceptibility to erosion/corrosion does increase;
: however, no further evaluation is required due to being adequately managed asdiscussed in Sections 3.5.1.1 and 10.7.2.[[i3.5.2.2 Other BOP Piping Systems3.5.2.2.1 Other BOP Piping Systems -RCIC, HPCS, LPCS, and RHR]] the loads and temperatures used in the analyses depend onthe containment hydrodynamic loads and temperature evaluation results (Section 4.1). [[]] The design basis LOCA dynamic loads including the pool swell loads, ventthrust loads, condensation oscillation (CO) loads, and chugging loads have been defined andevaluated for EPU. The pool temperatures due to a design basis LOCA were also defined forEPU. The values for the MELLLA+ operating domain remain within these bounding values.[[]] For these BOP piping systems,no further evaluation is required as a result of MELLLA+.The effect of MELLLA+ on the EPU AP load SC 09-01 evaluation has determined that the ARSremains conservative for the rated power MELLLA+ Point N (Figure 1-1). The off-rated SC 09-01 methods show minor shifts in the ARS for selected nodes (power-flow map Points Aand N in Figure 1-1) as compared to the EPU bounding spectrum.
The review of the EPUSC 09-01 AP load assessments show the minor shifts represent an insignificant change in thetotal load combination for these piping systems such that the conclusions reached for the EPUassessment remain unchanged.
The MELLLA+ operating domain expansion for NMP2 does not change the maximum operating temperature,
: pressure, or flow rate, or increase mechanical loads for any of the following systems:
RCIC, HPCS, LPCS, and RHR.RCIC, HPCS, LPCS, and RHR system temperatures, flows, and pressures at MELLLA+conditions are bounded by the EPU temperatures, flows, and pressures, and as such are withinthe design values used in the design of the piping and supports chosen for worst case conditions.
]] for each of the NMP2 systems described above, theloads and temperatures used in the analyses continue to be bounded by the loads and3-19 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)temperatures used in the analyses performed for EPU. Section 4.1 shows that the NMP2 LOCAdynamic loads including the pool swell loads, vent thrust loads, CO loads, and chugging loadshave been evaluated and are bounded by the current design basis. The NMP2 peak suppression pool temperatures due to a design basis LOCA are also bounded by the current design basis.]] For these BOP pipingsystems, no further evaluation is required as a result of MELLLA+.3.5.2.2.2 Other BOP Piping Systems -Offgas System, Containment Air Monitoring, and Neutron Monitoring System]] For these BOP piping systems, no further evaluation is required as a result ofMELLLA+.[[ ]] there is no change to the NMP2reactor operating pressure or power level as a result of MELLLA+ operating domain expansion.
The numerical values showing no increases in reactor operating pressure are presented inTable 1-2. [[]] For theseBOP piping systems, no further evaluation is required as a result of MELLLA+.Because all of the piping systems in Section 3.5.2.2 meet the criteria listed [[]] theirsusceptibility to erosion/corrosion does not increase, and no further evaluation of these otherBOP piping systems is required.
I[[3.6 REACTOR RECIRCULATION SYSTEMThe topics addressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultSystem Evaluation
[[Net Positive Suction Head (NPSH)Single Loop Operation Flow Mismatch
_ E3.6.1 System Evaluation
[[ ]] all of theRRS operating conditions for the MELLLA+ operating domain are within the operating conditions in the current licensed operating domain. SLO is not allowed in the MELLLA+3-20 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)operating domain. [[]] and no further evaluation of this topic is required.
]] the NMP2 RRS operating conditions in the MELLLA+ operating domain are within the operating conditions in the currentlicensed operating domain. For NMP2, there are no increases beyond design rated parameters inthe RRS temperature,
: pressure, or flow rates as a result of MELLLA+ operating domainexpansion as compared to the current licensed operating domain. RRS system temperature forthe current licensed operating domain at 100% CF is 533.7&deg;F and in the MELLLA+ operating domain at 85% CF is 530.7&deg;F.
RRS system pressures, at the discharge of the recirculation pump,will increase from 1,314.5 psia for the current licensed operating domain to 1,340.5 psia in theMELLLA+ operating domain. This slight increase in pressure is due to the adjustment of theFCV to approximately the 59% opened position and is within the design operating pressure ofthe RRS system components.
The numerical values showing no increases in RRS system flowrates are presented in Table 1-2. For NMP2, SLO is not allowed in the MELLLA+ operating domain. [[]] and no further evaluation ofthis topic is required.
3.6.2 Net Positive Suction Head]] Therefore, no further evaluation of the RRS NPSH topic is required.
3-21 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)]] flow rate and FW temperature and, as described above, they are not changed by MELLLA+.
[[]] The numerical values showing no significant changes in FW temperature and flow are presented in Table 1-2. Therefore, no furtherevaluation of the RRS NPSH topic is required.
3.6.3 Single Loop Operation
[[ ]] SLO is notallowed in the MELLLA+ operating domain.[[ ]] SLO is not allowed in the MELLLA+ operating domain. NMP2 SLO operational limitations will be identified in TS 3.4.1. Therefore, SLO isnot allowed in the MELLLA+ operating range and is not affected by the MELLLA+ domainexpansion.
3.6.4 Flow MismatchFlow mismatch is discussed in Section 4.3.8.3.7 MAIN STEAM LINE FLOW RESTRICTORS The topics addressed in this evaluation are:Topic " M+LTR Disposition NMP2 ResultStructural Integrity
]] there is no increase in MS flow as a result of the MELLLA+ operating domainexpansion.
[[]] and no further evaluation of this topic is required.
]] there is no increase in NMP2 MS flow as a resultof MELLLA+ operating domain expansion.
The numerical values showing that MS flow doesnot increase as a result of MELLLA+ are presented in Table 1-2. [[]] and no further evaluation ofthis topic is required.
3-22 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)3.8 MAIN STEAM ISOLATION VALVESThe topics addressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultIsolation Performance Valve Pressure Drop ]]]] there is no increase inMS pressure, flow, or pressure drop as a result of the MELLLA+ operating domain expansion.
[[ ]]and no further evaluation of this topic is required.
[[ ]] there is no significant change in NMP2 MSpressure, flow, or pressure drop as a result of MELLLA+ operating domain expansion.
The MSpressure for the current licensed operating domain and in the MELLLA+ operating domain is1,035 psia. The numerical values showing that MS flow does not increase as a result ofMELLLA+ are presented in Table 1-2. The total MSL pressure drop at the TSVs is notsignificantly changed for MELLLA+;
the MSIV pressure drop is also not significantly changed.[[i]] and no further evaluation of this topic is required.
1]3.9 REACTOR CORE ISOLATION COOLINGThe RCIC system provides inventory makeup to the reactor vessel when the vessel is isolatedfrom the normal high pressure makeup systems.
The topics addressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultSystem Hardware
[[System Initiation Net Positive Suction HeadInventory Makeup Level Margin to Top of Active Fuel (TAF) F3.9.1 System Hardwarethere are no changes to the RCIC system hardware as a result of MELLLA+ operating domainexpansion.
[[ ]] there are no changes to the NMP2 RCIC systemhardware as a result of MELLLA+.3-23 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)3.9.2 System Initiation
[[ ]] thereare no changes to the normal reactor operating
: pressure, decay heat, or SRV setpoints as a resultof MELLLA+ operating domain expansion.
[[no further evaluation of this topic is required.
]] there are no changes to the normal reactoroperating
: pressure, decay heat, or SRV setpoints as a result of MELLLA+ operating domainexpansion.
The NMP2 reactor operating pressure for the current licensed operating domain andin the MELLLA+ operating domain remain unchanged.
The numerical values showing thatreactor operating pressure does not increase as a result of MELLLA+ are presented in Table 1-2.As described in Section 1.2.3, the generic disposition in the M+LTR concludes that there is noincrease in decay heat as a result of MELLLA+ operating domain expansion.
As discussed inSection 3.1.2, SRV setpoints are unchanged by MELLLA+ operating domain expansion.
Therefore, for NMP2, [[]] No further evaluation of this topic is required.
3.9.3 Net Positive Suction Head[[ ]] the NPSHavailable for the RCIC pump [[]] For ATWS(Section 9.3) and fire protection (Section 6.7), operation of the RCIC system at suppression pooltemperatures greater than the operational limit may be accomplished by using the CST volume asthe source of water. Therefore, the specified operational temperature limit for the process waterdoes not change with MELLLA+.
The NPSH required by the RCIC pump [[]] Therefore, no further evaluation is required for this topic.]] for NMP2, there are no physical changes to thepump suction configuration.
The NMP2 RCIC flow rate for the current licensed operating domain and in the MELLLA+ operating domain is 600 gpm. Minimum atmospheric pressure in3-24 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)the suppression chamber and the CST for the current licensed operating domain and in theMELLLA+ operating domain does not change. The RCIC system has the capability of using theCST or the suppression pool as a suction source at EPU and MELLLA+ conditions.
For ATWS(Section 9.3) and fire protection (Section 6.7), operation of the RCIC system at suppression pooltemperatures greater than the operational limit may be accomplished by using the CST volume asthe source of the water. Therefore, the specified operational temperature limit for the processwater does not change with MELLLA+.
In addition, the MELLLA+ suppression pooltemperature following an ATWS is bounded by EPU.The design basis function of the RCIC system is to provide coolant to the reactor vessel so thatthe core is not uncovered as a result of loss of off-site alternating current (AC) power or for aloss of feedwater (LOFW) event.The NPSH required by the NMP2 RCIC pump [[]] Therefore, no furtherevaluation is required for this topic.3.9.4 Inventory Makeup Level Margin to TAFThe makeup capacity of RCIC and the level margin to the TAF are evaluated in Section 9.1.3.3.10 RESIDUAL HEAT REMOVAL SYSTEMThe RHR system is designed to restore and maintain the reactor coolant inventory following aLOCA and remove reactor decay heat following reactor shutdown for normal, transient, andaccident conditions.
The topics addressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultLow Pressure Coolant Injection ModeSuppression Pool and Containment Spray Cooling ModesShutdown Cooling (SDC) ModeSteam Condensing ModeFuel Pool Cooling Assist ]]The primary design parameters for the RHR system are the decay heat in the core and theamount of reactor heat discharged into the containment during a LOCA. The RHR systemoperates in various modes, depending on plant conditions.
[[]]3.10.1 Low Pressure Coolant Injection ModeThe LPCI mode, as it supports the LOCA response, is discussed in Section 4.2.4, Low PressureCoolant Injection.
3-25 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)3.10.2 Suppression Pool and Containment Spray Cooling Modes]] the SPC mode is manually initiated to maintain thecontainment pressure and suppression pool temperature within design limits following isolation transients or a postulated LOCA. The short-term containment
: response, for the first 30 secondsof the event, does not credit the containment spray in the analyses.
[[]] Therefore, no further evaluation is required for this topic.3.10.3 Shutdown Cooling Mode[]] theSDC mode is designed to remove the sensible and decay heat from the reactor primary systemduring a normal reactor shutdown.
This non-safety related mode allows the reactor to be cooleddown within a certain time, so that the SDC mode of operation does not become a critical pathduring refueling operations.
[[]] Therefore, no further evaluation is required for this topic.3.10.4 Steam Condensing ModeThe steam condensing mode is not applicable to NMP2.3.10.5 Fuel Pool Cooling Assist ModeThe fuel pool cooling assist mode, using existing RHR heat removal capacity, providessupplemental fuel pool cooling in the event that the fuel pool heat load exceeds the capability ofthe fuel pool cooling and cleanup system. [[]] Therefore, there is no effect on the fuel poolcooling assist mode.3.11 REACTOR WATER CLEANUP SYSTEMThe topics addressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultSystem Performance
[[Containment Isolation 3-26 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)3.11.1 System Performance ER]] the MELLLA+ operating domain expansion does not change the pressure or fluidthermal conditions experienced by the RWCU system. Operation in the MELLLA+ operating domain does not increase the quantity of fission products, corrosion
: products, and other solubleand insoluble impurities in the reactor water. Reactor water chemistry is within fuel warrantyand TS limits on effluent conductivity and particulate concentration, and thus, no changes will bemade in water quality requirements.
[[ ]] for NMP2, there is no totalincrease in the quantity of fission products, corrosion
: products, and other soluble and insoluble radionuclide impurities in the reactor water (see Section 8.4). Consistent with the genericdisposition discussed above, for NMP2, there is no significant change in the FW linetemperature,
: pressure, or flow rate. FW line temperature for the current licensed operating domain and in the MELLLA+ operating domain is 440.5'F (upstream of the RWCU return).
Asshown in Table 1-2, the FW flow rate in the MELLLA+ operating domain decreases slightlyfrom the flow rate in the current licensed operating domain. As discussed in Section 1.2, reactorpressure for the current licensed operating domain and in the MELLLA+ operating domain doesnot change. Therefore, FW system resistance and operating conditions do not change and thepressure at the RWCU/FW system interface does not change. As discussed in Sections 1.2 and3.6, reactor and recirculation system parameters are bounded by or unchanged from EPUconditions.
Therefore, there is no effect on RWCU inlet conditions due to MELLLA+.
Becausethere is no change to the pressure or fluid thermal conditions experienced by the RWCU system,and because there is no total increase in the quantity of fission products, corrosion
: products, andother soluble and insoluble radionuclide impurities in the reactor water, [[]] Therefore, no further evaluation of this topic is required.
3.11.2 Containment Isolation
]] the RWCU system is a normally operating system with no safety-related functions otherthan containment isolation.
[[]] because there is no change in the FW line pressure, temperature, and flow rate.[[ ]] for NMP2, there is no significant change in the FW line temperature,
: pressure, or flow rate. The FW line temperature for thecurrent licensed operating domain and in the MELLLA+ operating domain is 440.5'F (upstream of the RWCU return).
As shown in Table 1-2, the maximum FW flow rate in the MELLLA+operating domain decreases slightly from the maximum flow rate in the current licensedoperating domain. As such, the FW flow rates in the MELLLA+ operating domain remain3-27 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)within the FW flow rates in the current licensed operating domain. As discussed in Section 1.2,reactor pressure for the current licensed operating domain and in the MELLLA+ operating domain does not change. Therefore, FW system resistance and operating conditions do notchange and the pressure at the RWCU/FW system interface does not change for RWCU returnlines. As discussed in Section 3.11.1 above, there is no change to RWCU inlet conditions.
3-28 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Table 3-1 Key Results at 120% OLTPItem Parameter CLTP to M+120% OLTP Comparison I Azimuthal flux distribution at RPV ID Ratio of M+/CLTP peak flux is 0.982 Relative axial flux distribution at RPV ID No significant change3 Azimuthal flux distribution at shroud ID Ratio of M+/CLTP peak flux is 1.014 Relative axial flux distribution at shroud ID No significant change5 54-EFPY axial fluence distribution at RPV ID Ratio of M+/CLTP peak fluence is 0.996 54-EFPY axial fluence at shroud H4 weld Ratio of M+/CLTP peak fluence is 1.027 Capsule (30 azimuth) flux Ratio of M+/CLTP flux is 1.028 Capsule lead factor Ratio of M+/CLTP lead factor is 1.059 Peak flux at top guide Ratio of M+/CLTP peak flux is 1.0710 Peak flux at core plate Ratio of M+/CLTP peak flux is 0.9411 54-EFPY peak fluence at top guide Ratio of M+/CLTP peak fluence is 1.0612 54-EFPY peak fluence at core plate Ratio of M+/CLTP peak fluence is 0.943-29 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)4.0 ENGINEERED SAFETY FEATURESThis section addresses the evaluations that are applicable to MELLLA+.4.1 CONTAINMENT SYSTEM PERFORMANCE The topics addressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultShort-Term Pressure and Temperature ResponseLong-Term Suppression Pool Temperature ResponseContainment Dynamic LoadsLoss-of-Coolant Accident LoadsSubcompartment Pressurization Safety Relief Valve LoadsSafety Relief Valve Containment Dynamic LoadsSafety-Relief Valve Piping LoadsContainment Isolation Generic Letter 89-10Generic Letter 95-07Generic Letter 96-064.1.1 Short-Term Pressure and Temperature ResponseAccording to Section 4.1.1 of the M+LTR (Reference 1), operation in the MELLLA+ range maychange the break energy for the DBA recirculation suction line break (RSLB). The break energyis derived from the break flow rate and enthalpy.
[[]] NMP2 short-term RSLB containment temperature and pressure responses are affected by the change in enthalpy as a result of MELLLA+ operating domain expansion.
The short-term RSLB analyses cases at MELLLA+ demonstrate that peak DW temperatures from the short-term RSLB for the current licensed operating domain and the MELLLA+operating domain are bounded by the CLTP results reported in Reference 23 which remainbelow the design limit of 340'F.For NMP2, there are two peak pressures; the first peak occurring
-25 seconds (end of initialvessel inventory blowdown) and the second peak occurring
-150 seconds (end of blowdownphase). The first peak is typically determined by standard short-term
: analysis, while the secondpeak is determined by the extended short-term analysis.
The first peak is lower than the secondpeak; the difference is -0.5 psi for EPU. The extended short-term analysis is not sensitive to thesubtle initial changes in vessel mass and energy associated with operation at various points in theoperating domain. Due to the extended time frame until the DW reaches the second peakpressure conditions, it is recognized that the minor variability in the initial vessel inventory energy associated with various points in the operating range would have negligible effect in4-1 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)comparison to the overall mass and energy contributions to the DW at the time of the secondpeak. Therefore, the effect of MELLLA+ is assessed from the results of the standard short-term analysis using more detailed LAMB break flow model, which captures the subcooling effectwhen operating in MELLLA+ operating domain. Several short-term cases are analyzed forMELLLA+ statepoints and results compared to EPU short-term results.
The results show thatEPU short-term peak pressure bounds the MELLLA+ peak pressures.
The peak DW-to-wetwell differential pressures for operation in the MELLLA+ operating domain are bounded by thosepreviously reported in Reference 23 for the current CLTP operation.
[[]]4.1.1.1 Long-Term Suppression Pool Cooling Temperature ResponseTherefore, no further evaluation of this topic is required.
[[ ]] the sensible and decay heat do notincrease as a result of MELLLA+ operating domain expansion.
[[]] No further evaluation of thistopic is required.
4.1.2 Containment Dynamic Loads4.1.2.1 Loss-of-Coolant Accident LoadsAs described in the M+LTR, a [[ ]] evaluation is performed to determine theeffect of MELLLA+ on the LOCA containment dynamic loads. Results from [[]] are used to evaluate the effect of the MELLLA+ operating domain expansion onLOCA containment dynamic loads. The LOCA dynamic loads include vent clearing jet loads,pool swell, CO, and chugging.
4-2 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)These loads have been defined generically for Mark II plants as part of the Mark II containment program and are described in detail in the Mark II Containment Dynamic Forcing Functions Report (DFFR) (Reference 24). The DFFR was reviewed and approved by the NRC inNUREG-0808 and NUREG-0487 (References 9 and 25). The specific application of these loadsto NMP2 is described in Section 6A.4 of the NMP2 USAR (Reference 26).The results of the [[ ]] LOCA containment dynamic loads evaluation demonstrate that existing vent clearing jet loads, pool swell, CO, and chugging load definitions remainbounding for operation in the MELLLA+ operating domain. Therefore, the LOCA containment dynamic loads are not affected by the MELLLA+ operating domain expansion.
4.1.2.2 Subcompartment Pressurization Reduced FW temperature increases the subcooling in the FW and reactor recirculation lines,which increases the break flow rates for liquid line breaks. The current subcompartment pressurization loads evaluations consider the current licensed operating domain, which includesan operational band of-20'F (with a minimum FW temperature of 420.5&deg;F at rated power). Thisanalysis concludes that break flow rates for liquid line breaks such as FW and recirculation linebreaks for the MELLLA+ expanded operating domain are bounded by the break flow rates forthe current licensed operating domain. This operation band remains valid for the MELLLA+operating domain.4.1.2.2.1 Annulus Pressurization Load Evaluation The results from the updated dynamic analyses, including effects from both EPU and the non-conservative assumptions, were compared against those used as input to the component structural analyses of record. The effect of the increase in AP loads on the total component stresses is reduced when the AP loads are combined with the SSE seismic loads by the squareroot of the sum of the squares in the faulted load combination.
The SSE seismic loads in the loadcombination are not affected by EPU. The effect of MELLLA+ on the EPU AP load SC 09-01evaluation has determined that the ARS remains conservative for the rated power MELLLA+.The off-rated SC 09-01 methods show minor changes in the sub compartment pressurization related to the updated methods associated with SC 09-01 when combined with the jet reactionloads and jet impingement loads using conservative assumptions.
The minor changes in ARSfrequency when combined in the faulted load combination with seismic show that theconclusions reached for the EPU assessment remain bounding with a few locations showingminor increases.
The results of these evaluations show that all reactor vessel and internals, andassociated vessel attachments and supports remain within design basis faulted allowable limits.Because the MELLLA+ operating domain AP subcompartment pressurization are bound by thecurrent licensed operating domain, no further evaluation of this topic is required.
The evaluation of the NMP2-specific AP subcompartment pressurization is determined to beacceptable for NMP2.4-3 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)4.1.2.2.2 Drywell Head Subcompartment Pressurization Evaluation The pressure loading on the DW head refueling bulkhead plate to a postulated break in the RCIChead spray line in the DW head subcompartment is not affected by MELLLA+.
The pressureand temperature/enthalpy for the RCIC is either not affected or may be slightly reduced in valuecompared to EPU. The postulated RSLB in the DW affects the upward pressure loading on thebulkhead plate and remains bounded by the EPU evaluation as the fluid enthalpy at the breaklocation is not significantly affected (less than 1%), while the break location pressure is the sameas at CLTP. Therefore, the DW head refueling bulkhead plate design margins is unchanged.
Because the MELLLA+ operating domain DW head subcompartment pressurization is bound bythe current licensed operating domain, no further evaluation of this topic is required.
The evaluation of the NMP2-specific DW head subcompartment pressurization is determined tobe acceptable for NMP2.4.1.2.2.3 Biological Shield Wall Subcompartment Pressurization Evaluation The differential pressure loading on the biological shield wall (BSW) is not significantly affectedby MELLLA+.
The pressure and temperature/enthalpy for the high energy systems penetrating the BSW (recirculation, LPCS, HPCS, feedwater) are either not affected or may be slightlyreduced in value compared to EPU. The peak BSW differential pressure load resulting from thelimiting recirculation pump discharge line break at CLTP and MELLLA+ conditions remainsbounded by the EPU evaluations and remains below the BSW design differential pressure.
Inaddition, the EPU AP load SC 09-01 evaluation for the BSW remains conservative whenconsidering MELLLA+ and the off-rated operating conditions.
Because the MELLLA+ operating domain BSW subcompartment pressurization is bound by thecurrent licensed operating domain, no further evaluation of this topic is required.
The evaluation of the NMP2-specific BSW subcompartment pressurization is determined to beacceptable for NMP2.4.1.2.3 SRV Piping -Containment Dynamic Loadsbecause the sensible and decay heat do not change in the MELLLA+ operating domain, andbecause the SRV setpoints do not change, the SRV loads do not change. Therefore, no furtherevaluation of this topic is required.
[[ ]] the sensible and decay heat do notchange as a result of MELLLA+ operating domain expansion.
This response is discussed inSection 1.2.3. Also, there is no change to the NMP2 SRV setpoints as a result of MELLLA+operating domain expansion.
This topic is discussed in Section 3.1.2. Therefore, there is nochange to the NMP2 SRV loads. No further evaluation of this topic is required.
4-4 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)4.1.2.4 SRV -Containment Dynamic LoadsThe basis for the M+LTR (Reference
: 1) generic SRV containment load disposition wasconfirmed to be applicable to NMP2.Section 4.1 of the M+LTR (Reference
: 1) provides the following generic disposition for the effectof MELLLA+ on long-term suppression pool temperature response and SRV loads;4.1.3 Containment Isolation
]] evaluation is required todemonstrate the adequacy of the containment isolation system.]] Therefore, no containment isolation system evaluations are required forNMP2.[[4.1.4 Generic Letter 89-10Topic M+LTR Disposition NMP2 ResultGeneric Letter 89-10 [[Generic Letter 89-16Generic Letter 95-07Generic Letter 96-06 ]]]] evaluation toevaluate changes to the GL 89-10 program is required.
4-5 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)]] Sections 6.6 and 10.1 confirm that other parameters with the potential toaffect the capability of safety-related MOVs, such as the ambient temperature
: profile, arebounded by the current design basis. Therefore, a separate plant-specific GL 89-10 MOVprogram evaluation is not required.
4.1.5 Generic Letter 89-16GL 89-16 (Reference
: 28) is not applicable to NMP2.4.1.6 Generic Letter 95-07evaluation of the GL 95-07 program is required.
]] Therefore, no GL 95-07 evaluation is required.
4.1.7 Generic Letter 96-06[[Ievaluation of the GL 96-06 program is required.
[[]] Therefore, no GL 96-06 evaluation is required.
O[[4.2 EMERGENCY CORE COOLING SYSTEMSThe ECCS includes HPCS, the LPCS system, the LPCI mode of the RHR system, and the ADS.The topics addressed in this evaluation are:4-6 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Topic M+LTR Disposition NMP2 ResultHigh Pressure Coolant Injection N/A to NMP2 N/A to NMP2High Pressure Core SprayLow Pressure Core SprayLow Pressure Coolant Injection Mode of the Residual HeatRemoval SystemAutomatic Depressurization SystemEmergency Core Cooling System Net Positive Suction Head4.2.1 High Pressure Coolant Injection The HPCI system is not applicable to NMP2.4.2.2 High Pressure Core Spray[[ ]] the HPCSsystem is designed to spray water into the reactor vessel over a wide range of operating pressures.
In the event of a small break LOCA that does not immediately depressurize thereactor vessel, the HPCS system provides reactor vessel coolant inventory makeup to maintainreactor water level and help depressurize the reactor vessel. This system also provides spraycooling for long-term core cooling after a LOCA. In addition, the HPCS system serves as abackup to the RCIC system to provide makeup water in the event of a LOFW flow transient.
Forthe MELLLA+ operating domain expansion, there is no change in the normal reactor operating
: pressure, decay heat, and the SRV setpoints.
[[no further evaluation of the HPCSsystem is required.
[[ ]] there is no change to the normal reactor pressure asa result of MELLLA+ operating domain expansion.
The numerical values showing no increases in reactor operating pressure are presented in Table 1-2. The sensible and decay heat do notchange as a result of MELLLA+ operating domain expansion.
This response is discussed inSection 1.2.3. Also, there is no change to the NMP2 SRV setpoints as a result of MELLLA+operating domain expansion.
This topic is discussed in Section 3.1.2. [[]] and no further evaluation of the HPCS system is required.
4-7 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)4.2.3 Low Pressure Core Spray[I ]] the LPCS systemis automatically initiated in the event of a LOCA. The primary purpose of the LPCS system is toprovide reactor coolant makeup for a large break LOCA and for any small break LOCA after thereactor vessel has depressurized.
It also provides spray cooling for long-term core cooling in theevent of a LOCA. [[]] no further evaluation of the LPCS system for MELLLA+.]] there is no change to the reactor pressure as a resultof MELLLA+ operating domain expansion.
The numerical values showing no increases inreactor operating pressure are presented in Table 1-2. [[]] and no further evaluation of the LPCS system is required.
[[4.2.4 Low Pressure Coolant Injection
[[ ]] the LPCI mode of the RHRsystem is automatically initiated in the event of a LOCA. The primary purpose of the LPCImode is to provide reactor coolant makeup for a large break LOCA and for any small breakLOCA after the reactor vessel has depressurized.
[[]] no further evaluation ofLPCI for MELLLA+.[[ ]] there is no change to the reactor pressure as a resultof MELLLA+ operating domain expansion.
The numerical values showing no increases inreactor operating pressure are presented in Table 1-2. [[]) and no further evaluation of the LPCI mode is required.
In the event of a design basis4-8 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Appendix R event discussed in Section 6.7, the LPCI mode of RHR injects water into the reactorvessel to restore inventory and maintain core cooling following vessel depressurization.
[[4.2.5 Automatic Depressurization SystemR]] the ADS uses SRVs toreduce the reactor pressure following a small break LOCA, when it is assumed that the highpressure systems have failed. This allows the LPCS and LPCI systems to inject coolant into thereactor vessel. [[]] no further evaluation of the ADS isrequired.
[[]] and no further evaluation of the ADS is required.
Er4.2.6 ECCS Net Positive Suction HeadEr ]] theMELLLA+ operating domain expansion does not result in an increase in the heat addition to thesuppression pool following a LOCA, station blackout (SBO), or Appendix R event. [[]] There are nophysical changes in the piping or system arrangement.
There is no change in the operator actionsto throttle the RHR and CS pumps.Er ]] there is no increase in the heat addition to thesuppression pool following a LOCA, SBO, or Appendix R event (see Sections 4.1.2, 9.3.2, and6.7, respectively).
For NMP2, the most limiting case for ECCS NPSH is confirmed to occur atthe long-term suppression pool temperature during a LOCA, [[]] There are also no changes in NMP2 ECCS pipingor system arrangement.
There is no change in the operator actions to throttle the RHR and CSpumps. Therefore, all criteria related E[ ]] of ECCS-NPSH are met,and no further evaluation is required.
The suppression pool temperature following an ATWS is bounded by EPU.4-9 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)M+LTR SER Limitation and Condition 12.23.9 requires that plant-specific applications mustreview the safety system specifications to ensure that all of the assumptions used for the ATWSSE indeed apply to their plant-specific conditions including providing information on crucialsystems like HPCI and physical limitations like NPSH and maximum vessel pressure that RCICand HPCI can inject. NMP2 does not have a HPCI system. In response to an NRC RAI for theEPU LAR, NMP2 performed NPSH evaluation for ECCS pumps for variety of scenarios including DBA-LOCA and ATWS. The NPSH evaluation did not credit containment accidentoverpressure (Reference 31). As discussed above, MELLLA+ suppression pool temperature forDBA-LOCA is bounded by EPU. In addition, MELLLA+ ATWS suppression pool temperature is also bounded by EPU ATWS as shown in Table 9-4. Therefore, reduction in MELLLA+containment pressure has no effect on the ECCS pump operability in regard to NPSH.Therefore, NMP2 complies with M+LTR SER Limitation and Condition 12.23.9 related toNPSH and ECCS pump operability.
The EPU analysis of ECCS NPSH remains bounding for MELLLA+.
The NRC reviewed theECCS NPSH requirements as part of the EPU LAR, and stated in the NRC's SER for the NMP2EPU LAR dated December 22, 2011 (Reference
: 14) that the NMP2 ECCS NPSH meets theguidance in RG 1.1 (Reference 32), does not credit containment accident pressure to ensureadequate NPSH, and meets NRC staff guidance on NPSH uncertainty and operation in maximumerosion zone.4.3 EMERGENCY CORE COOLING SYSTEM PERFORMANCE The NMP2 ECCS is designed to provide protection against postulated LOCAs caused byruptures in the primary system piping. The ECCS performance characteristics do not change forthe MELLLA+ operating domain expansion.
The topics addressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultLarge Break Peak Clad Temperature Small Break Peak Clad Temperature Local Cladding Oxidation Core-Wide Metal Water ReactionCoolable GeometryLong-Term CoolingFlow Mismatch LimitsThese topics are described in Sections 4.3.2 through 4.3.8.4.3.1 Break Spectrum Response and Limiting Single Failure]] The break spectrum response is determined by the ECCS network design and iscommon to all BWRs. SAFER evaluation experience shows that the basic break spectrum4-10 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)response is not affected by changes in CF (Reference 33). [[M+LTR SER Limitation and Condition 12.14 requires that for plants that will implement MELLLA+,
a sufficient number of small break sizes shall be analyzed at the rated EPU powerlevel to ensure that the peak peak cladding temperature (PCT) break size is identified.
[[]]The factors influencing the selection of the limiting single failure for NMP2 are [[]] The trends discussed in the M+LTR regarding the first and second clad temperature peaks of large breaks are applicable to NMP2. [[]]The factors influencing the selection of the small break limiting single failure for NMP2 are4.3.2 Large Break Peak Clad Temperature The effect of MELLLA+ operating domain expansion on the NMP2 LOCA performance issimilar to that observed in the current licensed operating domain, which includes the MELLLAoperating domain low CF region. The PCT response following a large recirculation line breakhas two peaks. The first peak is determined by the boiling transition during CF coastdown earlyin the event. The second peak is determined by the core uncovery and reflooding.
MELLLA+ operating domain expansion has two effects on the boiling transition and first peakPCT. First, the reduced CF causes the boiling transition to occur earlier and lower in the bundle.Second, the reduced CF causes the initial subcooling in the downcomer to be higher so that thebreak flow is greater in the early phase of the LOCA event. For a given power level, the earlyboiling transition times (boiling transitions that occur before jet pump uncovery) for NMP2occur earlier in the event and penetrate lower in the fuel bundle as the CF is reduced, but theeffect of the early boiling transition on the LOCA PCT depends on the particular conditions.
Effect of MELLLA+ at Rated PowerThe PCT results are shown in the table at the end of this section.
[[4-11 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Effect of MELLLA+ at Less Than Rated PowerM+LTR SER Limitation and Condition
: 12. 1O.a requires the M+SAR to provide a discussion onthe power/flow combination scoping calculations that were performed to identify the limitingstatepoints in terms of DBA-LOCA PCT response for the operation within the MELLLA+boundary.
As required by this limitation,
[[]] The PCT results summarized below show that there are no unusualtrends in PCT in the MELLLA+ region and that there is margin to the 2,200'F PCT limit.Effect of Axial Power ShaveAs required by M+LTR SER Limitation and Condition 12.11 (Reference
: 1) and Methods LTRSER Limitation and Condition 9.7 (Reference
: 3) for MELLLA+ applications, the small and largebreak ECCS-LOCA analyses shall include top-peaked and mid-peaked power shape inestablishing the MAPLHGR and determining the PCT. This limitation is applicable to both thelicensing basis PCT and the upper bound PCT. The plant-specific applications should report thelimiting small and large break licensing basis and upper bound PCTs. [[4-12 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Power/Flow' Nominal PCT (OF) 2  Appendix K PCT (OF) 21st Peak 2nd Peak 1st Peak 2nd PeakNotes: 1 Power level shown is percent at EPU condition.
Flow level shown is percent of RCF.2 Results are for GE14 DBA large break.4.3.3 Small Break Peak Clad Temperature I[[Effect of MELLLA+ at Rated PowerThe PCT results are shown in the table at the end of this section.
[[1]]M+LTR SER Limitation and Condition 12.13 requires that the MELLLA+ plant-specific SARinclude calculations for the limiting small break at rated power/RCF and rated power/MELLLA+
: boundary, if the small break PCT at rated power/RCF is within [[ ]] of the limitingAppendix K PCT. For NMP2, the small break PCT is limiting.
Therefore, small break PCTcalculations are performed for MELLLA+ flow, and the PCT results are shown in the table at theend of this section.Effect of MELLLA+ at Less Than Rated PowerM+LTR SER Limitation and Condition 12.1O.b requires that the M+SAR provide a justification as to why the transition statepoint ECCS-LOCA response bounds the 55% CF statepoint.
]] The PCT results4-13 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)summarized below show that there are no unusual trends in PCT in the MELLLA+ region andthat there is margin to the 2,200'F PCT limit.Effect of Axial Power ShapeAs required by M+LTR SER Limitation and Condition 12.11 and Methods LTR SER Limitation and Condition 9.7 for MELLLA+ applications, the small and large break ECCS-LOCA analyseshave included top-peaked and mid-peaked power shapes in establishing the MAPLHGR anddetermining the PCT. This limitation is applicable to both the licensing basis PCT and the upperbound PCT. The plant-specific applications have confirmed that the limiting small and largebreak with [[]]Small Break Licensing Basis PCTReference 34 provides justification for the elimination of the 1,600'F upper bound PCT limit andgeneric justification that the licensing basis PCT will be conservative with respect to the upperbound PCT. The NRC SER in Reference 34 accepted this position by noting that, because plant-specific upper bound PCT calculations have been performed for all plants, other means may beused to demonstrate compliance with the original SER limitations.
These other means areacceptable provided there are no significant changes to a plant's configuration that wouldinvalidate the existing upper bound PCT calculations.
The changes in magnitude of the PCT dueto MELLLA+ demonstrate that this plant configuration change does not invalidate the existingupper bound PCT calculations.
M+LTR SER Limitations and Conditions 12.12.a and 12.12.b and Methods LTR SER Limitation and Condition 9.8 also require that the ECCS-LOCA evaluation be performed for all statepoints in the upper boundary of the expanded operating domains.
[[]] The calculated GEl4 licensing basis PCT is 1,580'F, based on the limiting casescenario.
[[4-14 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Power/Flow' Nominal PCT (*F)2 Appendix K PCT (OF)2Notes:Power level shown is percent at EPU power level. Flow level shown is percent of RCF.2 Results are for GEl4 limiting small break.4.3.4 Local Cladding Oxidation Er]] Sections 4.3.2 and 4.3.3 that determine the effect on the PCT. [[]] and no further evaluation of this topic is required.
Er ]] for NMP2, Sections 4.3.2 and4.3.3 show acceptable PCT results that meet the 2,200'F limit. [[]] and no furtherevaluation of this topic is required.
[[4.3.5 Core-Wide Metal Water Reaction]] Sections 4.3.2 and 4.3.3 that determine the effect on the PCT. [[]] and no further evaluation of this topic is required.
]] for NMP2, Sections 4.3.2 and4.3.3 show acceptable PCT results that meet the 2,200'F limit. [[]] and no furtherevaluation of this topic is required.
4-15 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)4.3.6 Coolable Geometry]] NMP2's compliance with thecoolable geometry acceptance criteria was generically demonstrated as a GEH BWR [[4.3.7 Long-Term Cooling]] NMP2's compliance with the long-term cooling acceptance criteria was generically demonstrated as a GEH BWR [[4.3.8 Flow Mismatch Limitslimits have been placed on recirculation drive flow mismatch over a range of CFs. For mostplants, the limits on flow mismatch are more relaxed at lower CF rates. The drive flowmismatch affects the CF coastdown following the break. The effect of the drive flow mismatchon the LOCA evaluation is similar to a small change in the initial CF. [[]] the discussion and trends in theM+LTR are applicable to NMP2. [[4-16 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)]]4.4 MAIN CONTROL ROOM ATMOSPHERE CONTROL SYSTEMThe topics addressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultIodine Intake[[ ]] theMELLLA+ operating domain expansion does not result in a change in the source terms or therelease rates (Section 8.0). [[]] Provided this criterion ismet, no further evaluation of the Main Control Room (MCR) atmosphere control system isrequired.
[[ ]] there is no change in the NMP2source term or release rates as a result of MELLLA+ operating domain expansion.
This topic isdiscussed in Section 8.0. [[]] No further evaluation ofthe MCR atmosphere control system is required.
I[[4.5 STANDBY GAS TREATMENT SYSTEMThe topics addressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultFlow CapacityIodine Removal Capability 4.5.1 Flow Capacity[ ]]theSGTS is designed to maintain secondary containment at a negative pressure and to filter theexhaust air for removal of fission products potentially present during abnormal conditions.
Bylimiting the release of airborne particulates and halogens, the SGTS limits off-site dose following a postulated DBA. [[]] and no furtherevaluation of the SGTS flow is required.
[[ ]] the design flow capacity of theNMP2 SGTS was selected to maintain the secondary containment at the required negativepressure to minimize the potential for exfiltration of air from the Reactor Building.
[[4-17 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)]] and no further evaluation is required.
4.5.2 Iodine Removal Capability
[[]] the SGTS is designed to maintain secondary containment at a negative pressure and tofilter the exhaust air for removal of fission products potentially present during abnormalconditions.
By limiting the release of airborne particulates and halogens, the SGTS limits off-site dose following a postulated DBA. [[]] the core fission product inventory isnot changed by the MELLLA+ operating domain expansion (Section 8.3), and coolant activitylevels are defined by TS and do not change, so no change occurs in the SGTS adsorber iodineloading, decay heat rates, or iodine removal efficiency.
[[]] No further evaluation of this topic is required.
4.6 MAIN STEAM ISOLATION VALVE LEAKAGE CONTROL SYSTEMNMP2 does not use a MSIV leakage control system (LCS).4.7 POST-LOCA COMBUSTIBLE GAS CONTROL SYSTEMThe topics addressed in this evaluation are:M+LTRTopic NMP2 ResultPost-LOCA Combustible Gas Control ]]10 CFR 50.44 was revised in September 2003 and no longer defines a design basis LOCAhydrogen release.
This new revision eliminates the requirements for hydrogen control systems tomitigate such a release.
NMP2 has adopted the revised ruling per NMP2 license amendment Number 124, issued in April 2008, which relaxed the requirements for hydrogen and oxygenmonitoring.
This amendment also eliminated the requirements for hydrogen recombiners for thepurpose of mitigating post-LOCA hydrogen
: release, although NMP2 has chosen to leave therecombiners in place and remain functional.
NMPNS made commitments to maintain thehydrogen and oxygen monitoring systems capable of diagnosing beyond DBAs. MELLLA+operating domain expansion has no effect on the design of these systems or on the ability ofthese systems to perform their intended functions.
: However, as this system is no longer required4-18 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)to be maintained as a post-LOCA combustible gas control system, no further evaluation isnecessary relative to the MELLLA+ operating domain expansion.
The generic disposition of thesystem (under the M+LTR) is no longer applicable.
[[4-19 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)5.0 INSTRUMENTATION AND CONTROLThis section addresses the evaluations that are applicable to MELLLA+.5.1 NSSS MONITORING AND CONTROLChanges in process parameters resulting from the MELLLA+ operating domain expansion andtheir effects on instrument performance are evaluated in the following sections.
The effect of theMELLLA+ operating domain expansion on the TS is addressed in Section 11.1 and the effect onthe allowable values (AVs) in Section 5.3. The topics addressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultAverage Power Range, Intermediate Range,and Source Range MonitorsLocal Power Range MonitorsRod Block MonitorRod Worth Minimizer Traversing Incore Probes5.1.1 Average Power Range, Intermediate Range, and Source Range MonitorsI[[]] the APRM output signals are calibrated to read 100% at the CLTP.]] Using normal plant surveillance procedures, the IRMs may be adjusted to ensure adequate overlap with the SRMs and APRMs.Therefore, no further evaluation of the APRMs, IRMs, or SRMs is required for MELLLA+.[[ ]] there is no change in NMP2 corepower as a result of MELLLA+ operating domain expansion.
[[]] TheAPRMs, IRMs, and SRMs are installed at NMP2 in accordance with the requirements established by the GEH design specifications.
NMP2 uses normal plant procedures to adjust theIRMs to ensure adequate overlap with the SRMs and APRMs. Therefore, no further evaluation is required.
5.1.2 Local Power Range Monitors[[ ]] there is nochange in the neutron flux experienced by the LPRMs resulting from the MELLLA+ operating domain expansion.
[[5-1 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)]] No further evaluation of these topics is requiredfor MELLLA+.[[ ]] there is no change in the neutronflux experienced by the NMP2 LPRMs resulting from the MELLLA+ operating domainexpansion.
Analysis was performed to confirm that bypass voiding at the D Level LPRM doesnot exceed 5%. Therefore,
[[]] The LPRMs are installed at NMP2 in accordance with therequirements established by the GEH design specifications.
No further evaluation of these topicsis required for MELLLA+.1]]5.1.3 Rod Block MonitorsEr ]] the RBM usesLPRM instrumentation inputs that are combined and referenced to an APRM channel.
[[]] and as described in Sections 5.1.1and 5.1.2, the [[]] No further evaluation ofthese topics is required for MELLLA+.Section 9.1.1 evaluates the adequacy of the generic RBM setpoints.
Er5.1.4 Rod Worth Minimizer
]] the function of the RWM is to support the operator by enforcing rod patterns untilreactor power has reached appropriate levels. The RWM functions to limit the local power in thecore to control the effects of the postulated control rod drop accident (CRDA) at low power.E[ r]Therefore, no further evaluation is required.
[[ ]] the NMP2 RWM supports theoperator by enforcing rod patterns until reactor power has reached appropriate levels.E[ r]Therefore, no further evaluation is required.
E[5-2 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)5.1.5 Traversing Incore ProbesTo address the M+LTR SER Limitation and Condition 12.15, bypass voiding above the D-Level,an analysis was performed to identify the region on the MELLLA+ power/flow map that haspotentially unacceptable bypass voiding for the thermal traversing incore probes (TIPs) installed at NMP2. In the absence of bypass voiding greater than 5% no actions are required regarding theTIPs resulting from the MELLLA+ operating domain expansion.
[[Analysis shows that there is a small region of the MELLLA+ power flow domain near point Min Figure 5-1 where the hot channel voiding at the TIP exit exceeds 5% thus requiring specificattention per Limitation and Condition 12.15. [[]] TIP operation and LPRM calibration in the remainder of the MELLLA+domain are not adversely affected by the void conditions in the bypass region. NMPNS controlroom operators and Reactor Engineers will be trained on this requirement and station procedures will be modified accordingly.
[[ ]] there is no change in the neutronflux experienced by the NMP2 TIPs resulting from the MELLLA+ operating domain expansion.
[[ ]] The TIPs are installed at NMP2 inaccordance with the requirements established by the GEH design specifications.
No furtherevaluation of these topics is required for MELLLA+.[ 1]]5.2 BOP MONITORING AND CONTROLOperation of the plant in the MELLLA+ domain has no effect on the BOP systeminstrumentation and control devices.
The topics addressed in this evaluation are:5-3 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Topic M+LTR Disposition NMP2 ResultPressure Control SystemTurbine Steam Bypass System (Nomial Operation)
Turbine Steam Bypass System (Safety Analysis)
Feedwater Control System (Normal Operation)
Feedwater Control System (Safety Analysis)
Leak Detection System _]5.2.1 Pressure Control System]] Therefore, no further evaluation of this system isrequired as a result of MELLLA+.[[ ]] for NMP2, there are no increases in reactor operating
: pressure, MS or FW flow rates. The numerical values showing no increases in reactor operating
: pressure, MS or FW flow rates are presented in Table 1-2. The systemdynamic characteristics of the NMP2 pressure control system are not changed.
[[]] Therefore, no further evaluation of thissystem is required as a result of MELLLA+.5.2.2 Turbine Steam Bypass System (Normal Operation)
]] Therefore, no further evaluation ofthis system is required as a result of MELLLA+.[[ ]] for NMP2, there are no increases in reactor operating
: pressure, MS or FW flow rates. The numerical values showing no increases in reactor operating
: pressure, MS or FW flow rates are presented in Table 1-2. The systemdynamic characteristics of the NMP2 turbine steam bypass system under normal operation arenot changed.
[[]] Therefore, no further evaluation of this system is required as a result of MELLLA+.5-4 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)5.2.3 Turbine Steam Bypass System (Safety Analysis)
]] Therefore, no further evaluation ofthis system is required as a result of MELLLA+.[R ]] for NMP2, there are no increases in reactor operating
: pressure, MS or FW flow rates. The numerical values showing no increases in reactor operating
: pressure, MS or FW flow rates are presented in Table 1-2. The systemdynamic characteristics of the NMP2 turbine steam bypass system in safety analysis conditions are not changed.
[[1]]Therefore, no further evaluation of this system is required as a result of MELLLA+.[[I5.2.4 Feedwater Control System (Normal Operation)
[[I]] Therefore, no further evaluation of this systemis required as a result of MELLLA+.R]] for NMP2, there are no increases in reactor operating
: pressure, MS or FW flow rates. The numerical values showing no increases in reactor operating
: pressure, MS or FW flow rates are presented in Table 1-2. The systemdynamic characteristics of the NMP2 FW control system under normal operation are notchanged.
[[]] Therefore, no furtherevaluation of this system is required as a result of MELLLA+.[[I5.2.5 Feedwater Control System (Safety Analysis)
]] Therefore, no further evaluation of this systemis required as a result of MELLLA+.[[ ]] for NMP2, there are no increases in reactor operating
: pressure, MS or FW flow rates. The numerical values showing no increases in reactor operating
: pressure, MS or FW flow rates are presented in Table 1-2. The system5-5 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)dynamic characteristics of the NMP2 FW control system in safety analysis conditions are notchanged.
[[]] Therefore, no furtherevaluation of this system is required as a result of MELLLA+.[[5.2.6 Leak Detection System]] Therefore, no further evaluation of this system isrequired as a result of MELLLA+.[[ ]] for NMP2, there are no increases in reactor operating
: pressure, MS or FW flow rates. In addition, RWCU, RHR, HPCS, andRCIC pressures, temperatures, and flows are unchanged.
The numerical values showing noincreases in reactor operating
: pressure, MS or FW flow rates are presented in Table 1-2. Inaddition, as discussed in Section 4.1.2, suppression pool time history response temperatures inthe MELLLA+ operating domain are bounded by the EPU results.
Therefore, the systemdynamic characteristics of the NMP2 leak detection system are not changed.
[[]] Therefore, no further evaluation of thissystem is required as a result of MELLLA+.5.3 TECHNICAL SPECIFICATION INSTRUMENT SETPOINTS The TS instrument AVs and the nominal trip setpoints (NTSPs) are those sensed variables whichinitiate protective actions and are generally associated with the safety analysis.
Thedetermination of the AV and NTSP includes consideration of measurement uncertainty and arederived from the AL. Standard GEH setpoint methodology (Reference
: 35) is used to generatethe AV and NTSPs from the related ALs.The MELLLA+ operating domain expansion results in the development of two ALs.GEH typically uses the approved simplified process to determine the instrument AVs and NTSPsfor MELLLA+ applications.
The NRC staff has previously reviewed and accepted the simplified approach in the review of NEDC-33004P-A (Reference 7). Consistent with that approval, forNMP2 the following criteria are satisfied for using the simplified process:1. [[2. NRC approved GEH or plant-specific methodologies are used (Reference 35).5-6 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)3. [[However, complete setpoint calculations, using the setpoint methodology described inReference 35 have been performed for the APRM Flow Biased Scram and Rod Block for TLO,to better support NMP2 in implementing the guidance provided by Regulatory Issue Summary(RIS) 2006-17 (Reference
: 36) and Technical Specification Task Force (TSTF)-493 (Reference 37).The topics addressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultAPRM Flow-Biased Scram [[Rod Block Monitor5.3.1 APRM Flow-Biased ScramThe MELLLA+ APRM Flow Biased STP Scram AL line is established to [[]]The MELLLA+ APRM Flow Biased STP AL expressions are:ALM+ROD BLOCK = 0.61W + 60.1%, for the Rod Block, andALM+sCRAM
= 0.6 1W + 66.1%, for the Scram.SLO is not applicable to the MELLLA+ operating domain as discussed in Section 3.6.3.Therefore, the SLO setpoints are unchanged.
The evaluation of APRM Flow Biased STP Scram setpoints is consistent with the methodsdescribed for [[ ]] this topic in the M+LTR. The APRM FlowBiased STP Scram setpoints for the NMP2 [[ are therefore acceptable.
5.3.2 Rod Block Monitor[]] the RBM setpoints are established to mitigate the rod withdrawal error (RWE) event during power operation.
For plants with ARTS RBM systems,
[[5-7 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)]] Therefore, no further evaluation of theRBM TS values is required as a result of MELLLA+.[[ ]] for NMP2, there is no change inreactor power level as a result of MELLLA+ operating domain expansion.
NMP2 has an ARTSRBM system. [[Therefore, no further evaluation of the RBM TS values is required as a result of MELLLA+.5-8 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)I[Figure 5-1 NMP2 EPUIM+ Power/Flow Map with 5% Voiding at the TIP Exit Boundary5-9 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)6.0 ELECTRICAL POWER AND AUXILIARY SYSTEMSThis section addresses the evaluations that are applicable to MELLLA+.
Because there is nochange in power output, most of the topics in this section are unaffected by the MELLLA+operating domain expansion.
6.1 AC POWERThe AC power supply includes both off-site and on-site power. The on-site power distribution system consists of transformers, buses, and switchgear.
AC power to the distribution system isprovided from the transmission system or from on-site D/Gs. The topics addressed in thisevaluation are:Topic M+LTR Disposition NMP2 ResultAC Power (Normal or Degraded Voltage)]] there is no change in the thermal power from the reactor or the electrical output from the station that results from the MELLLA+ operating domain expansion.
[[No further evaluation of the AC Power system is required.
[[ ]] there is no change in the NMP2reactor thermal power or the electrical output from the station that results from the MELLLA+operating domain expansion.
[[No further evaluation of the AC Power system is required.
]]6.2 DC POWERThe direct current (DC) power distribution system provides control and motive power for varioussystems/components within the plant. The topics addressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultDC PowerEr ]] theMELLLA+ operating domain expansion does not change system requirements for control or6-1 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)motive power loads. [[further evaluation of this topic is required.
[R]] Therefore, no]] as a result of MELLLA+ operating domain expansion.
The MELLLA+operating domain expansion does not change system requirements for control or motive powerloads. Therefore, no further evaluation of the DC Power system is required.
6.3 FUEL POOLThe topics addressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultFuel Pool Cooling:[
Crud Activity and Corrosion ProductsRadiation LevelsFuel Racks ]6.3.1 Fuel Pool Cooling_1MELLLA+ operating domain expansion does not increase the core power level. [[]] the]] No furtherevaluation of the fuel pool cooling systems are required for MELLLA+ operating domainexpansion.
[[ ]] NMP2 reactor power level doesnot increase as a result of MELLLA+ operating domain expansion.
[[]] No further evaluation of theNMP2 fuel pool cooling systems is required for MELLLA+ operating domain expansion.
1]6.3.2 Crud Activity and Corrosion Products]] No further evaluation of the crud and corrosion products in the spent fuelpools is required for MELLLA+ operating domain expansion.
]] Therefore, no further evaluation of the crud and corrosion products in the spentfuel pools is required for the NMP2 MELLLA+ operating domain expansion.
6-2 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)6.3.3 Radiation Levels[[]] No further evaluation of the radiation levels in the spent fuel pools isrequired for MELLLA+ operating domain expansion.
[[Therefore, no further evaluation of the radiation levels in the spent fuel pools is required for theNMP2 MELLLA+ operating domain expansion.
Er6.3.4 Fuel RacksEr ]] the MELLLA+operating domain expansion does not increase the core power level. [[]] No furtherevaluation of the fuel racks is required for MELLLA+ operating domain expansion.
[[ ]] the MELLLA+ operating domainexpansion does not increase the NMP2 core power level. [[]] No furtherevaluation of the fuel racks is required for MELLLA+ operating domain expansion.
6.4 WATER SYSTEMSThe water systems are designed to provide a reliable supply of cooling water for normaloperation and DBA conditions.
The topics addressed in this evaluation are:Topic M+LTR Disposition NMP2 Result]Water SystemsEE ]]theperformance of the safety-related service water system during and following the most limitingdesign basis event, the LOCA, is not affected by the MELLLA+ operating domain expansion.
Er]] No furtherevaluation of water systems is required for MELLLA+.6-3 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)]] for NMP2, the MELLLA+operating domain expansion does not affect the performance of the safety-related emergency service water system or the RHR service water system during and following the most limitingdesign basis event, the LOCA, as discussed in Section 4.3. [[]] No further evaluation of the NMP2 water systems is required for MELLLA+operating domain expansion.
6.5 STANDBY LIQUID CONTROL SYSTEMThe SLS is an automatic or manually operated system that pumps a sodium pentaborate solutioninto the vessel to provide neutron absorption and achieve a subcritical reactor condition in thesituation where none of the control rods can be inserted.
The topics addressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultShutdown Margin [[System HardwareATWS Requirements
]]6.5.1 Shutdown MarginI[[]]Anincrease in the reactor boron concentration may be achieved by increasing, either individually orcollectively, (1) the minimum solution volume, (2) the minimum specified solutionconcentration, or (3) the isotopic enrichment of the B10 in the stored neutron absorber solution.
In order to account for reactivity variations between cycles, the USAR Section 9.3.5 limit forreactor coolant boron concentration has sufficient margin to accommodate most core designvariations.
]] Because no new fuel product linedesigns are introduced for MELLLA+ operating domain expansion, the USAR Section 9.3.5limit for minimum reactor coolant boron concentration of 780 ppm natural boron does notchange as a result of MELLLA+ operating domain expansion.
NMP2 calculates SLS shutdownmargin as a part of the core reload analysis.
Therefore, no further evaluation of SLS shutdownmargin is required for MELLLA+.6-4 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)6.5.2 System HardwareM+LTR describes that the SLS is typically designed for injection at a maximum reactor pressureequal to the upper analytical setpoint for the lowest group of SRVs operating in the relief mode.1]The NMP2 reactor operating pressure is unchanged by MELLLA+ operating domain expansion.
The numerical values showing no increases in reactor operating pressure are presented inTable 1-2. As discussed in Section 3.1.2, there are no changes to the NMP2 SRV setpoints as aresult of MELLLA+ operating domain expansion.
Because the reactor dome pressure and SRVsetpoints are unchanged for MELLLA+,
the SLS process parameters do not change. Therefore, the capability of the SLS to perform its shutdown function is not affected by MELLLA+.
[[]] Therefore, the NMP2 SLS remains capable of performing itsshutdown function.
[[ Er6.5.3 ATWS Requirements As described in the M+LTR, the SLS ATWS performance is evaluated in Section 9.3.1 [[]] The representative MELLLA+ evaluation shows that the SLS maintains the capability to mitigate an ATWS andthat the current boron injection rate is sufficient relative to the peak suppression pooltemperature.
The ATWS analysis in Section 9.3.1 also demonstrates that there is no increase inthe peak vessel dome pressure during the time the SLS is in operation.
Er]] The pressure margin for the pump discharge relief valvesremains above the minimum value needed to ensure that the SLS relief valves remain closedduring system injection.
Because NMP2 does not take credit for the operation of the SRVs in apower actuated relief mode during an ATWS, the peak reactor pressures for the loss of off-sitepower (LOOP) event would be the bounding ATWS event. The minimum reactor pressure, justprior to the time when SLS initiates, remains low enough to ensure SLS relief valve closure priorto the analyzed SLS initiation time in the event of an early initiation of the SLS during the initialATWS transient pressure response.
Consequently, the current NMP2 SLS process parameters associated with the minimum boron injection rate do not need to change. Therefore, SLSoperation during an ATWS is not affected by the MELLLA+ operating domain expansion.
6-5 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)6.6 HEATING, VENTILATION AND AIR CONDITIONING The heating, ventilation, and air conditioning (HVAC) systems consist mainly of heating,cooling supply, exhaust and recirculation units in the Turbine Building, Reactor Building, DW,Control Building, and the Radwaste Building.
The topics addressed in this evaluation are:Topic I M+LTR Disposition NMP2 ResultHeating, Ventilation, and Air Conditioning I]][]] the processtemperatures and heat load from motors and cables do not change due to MELLLA+ operating domain expansion.
[[]] No further evaluations of the HVAC system are required for MELLLA+operating domain expansion.
]] for NMP2, HVAC systems, theprocess temperatures and heat load from motors and cables are bounded by the EPU processtemperatures and heat loads and as such are within the design of the HVAC equipment chosenfor worst case conditions.
[[]] No further evaluations of the NMP2 HVAC systems arerequired for MELLLA+ operating domain expansion.
6.7 FIRE PROTECTION This section addresses the fire protection
: program, fire suppression and detection
: systems, andsafe shutdown system responses to postulated 10 CFR 50 Appendix R fire events. The topicsaddressed in this evaluation are:Topic M+LTR Disposition NNMP2 ResultFire Protection
[]] becausethe decay heat does not change for the MELLLA+ operating domain expansion, there are nochanges in vessel water level response, operator response time, PCT, and peak suppression pooltemperature and containment pressure.
[[Provided the above criteria are met, no further evaluation of fire protection is required forMELLLA+ operating domain expansion.
[[ ]] for NMP2, these parameters donot change as a result of MELLLA+ operating domain expansion.
As discussed in Section 1.2.3,decay heat does not change as a result of MELLLA+ operating domain expansion.
Reactor6-6 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)vessel water level response is unchanged by MELLLA+ operating domain expansion.
Operatorresponse times are not affected by MELLLA+ because:
[[]] The effect ofMELLLA+ operating domain expansion on PCTs is evaluated to be acceptable in Section 4.3.The effect of MELLLA+ operating domain expansion on peak suppression pool temperatures and containment pressure response are evaluated and concluded to be bounded by EPUconditions in Section 4.1. [[]] and no further evaluation of fire protection is required forMELLLA+ operating domain expansion.
6.8 OTHER SYSTEMS AFFECTEDThe topics addressed in this evaluation are other systems that may be affected by the MELLLA+operating domain expansion:
Topic M+LTR Disposition NMP2 ResultOther Systemsthe systems typically found in a BWR power plant have been evaluated to establish thosesystems that are affected by the MELLLA+ operating domain expansion.
Those systems that aresignificantly affected by the MELLLA+ operating domain expansion are addressed in this report.Other systems not addressed by this report are not significantly affected by the MELLLA+operating domain expansion.
]] the NMP2 systems evaluated
[[were reviewed for MELLLA+ operating domainexpansion to ensure that all significantly affected systems were addressed.
This topic confirmsthat those systems that are significantly affected by the MELLLA+ operating domain expansion are addressed in this report. Other systems not addressed by this report are not significantly affected by the MELLLA+ operating domain expansion.
6-7 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)7.0 POWER CONVERSION SYSTEMSThis section addresses the evaluations that are applicable to MELLLA+.
Because the pressure, steam and FW flow rates, and FW fluid temperature ranges are not significantly changed by theoperating domain expansion, the power conversion systems are unaffected.
7.1 TURBINE-GENERATOR The turbine-generator converts the thermal energy in the steam into electrical energy. The topicsaddressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultTurbine-Generator
[ ]]theMELLLA+ operating domain expansion does not change the pressure, thermal energy, and steamflow from the reactor.
: Likewise, there is no change in the electrical output of the generator.
No further evaluation of this topic is required.
[[ ]] there is no change in the reactorpower level as a result of MELLLA+ operating domain expansion.
For NMP2, there are noincreases in reactor operating pressure or MS flow rates. The numerical values showing noincreases in reactor operating pressure and MS flow rates are presented in Table 1-2. Theelectrical output in the current licensed operating domain and in the MELLLA+ operating domain is approximately 1,368.9 MWe. Therefore,
[[]] No furtherevaluation of this topic is required.
7.2 CONDENSER AND STEAM JET AIR EJECTORSThe condenser removes heat from the steam discharged from the turbine and provides liquid forthe condensate and FW systems.
The steam jet air ejectors remove non-condensable gases fromthe condenser to improve thermal performance.
The topics addressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultCondenser Steam Jet Air Ejectors]] the MELLLA+ operating domain expansion does not change the steam flowrate or power level. [[]] there is no change in the reactorpower level as a result of MELLLA+ operating domain expansion.
For NMP2, there are no7-1 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)increases in reactor operating pressure or MS flow rates. The numerical values showing noincreases in reactor operating pressure and MS flow rates are presented in Table 1-2.[[]] MELLLA+ operating domainexpansion does not affect the condenser, and no further evaluation is required.
MELLLA+ may increase the amount of moisture reaching the steam jet air ejectors motive steaminlet for short periods of time. The steam jet air ejectors would acceptably function because themaximum expected moisture at the steam jet air ejectors would be less than the typical industryguideline limit of 1 wt.% under the worst case moisture content at the inlet nozzles.
The steamjet air ejectors will acceptably function in the MELLLA+ domain.[[]] The evaluation of the NMP2 steam jet air ejector is acceptable for MELLLA+ operation.
7.3 TURBINE STEAM BYPASSThe turbine steam bypass system provides a means of accommodating excess steam generated during normal plant maneuvers and transients.
The topics addressed in this evaluation are:Topic M+LTR Disposition NMP2 Result]Turbine Steam Bypassthere is no change in the power level, pressure or steam flow for the MELLLA+ operating domain expansion.
Therefore, MELLLA+ operating domain expansion does not affect theturbine steam bypass system, and no further evaluation is required.
Er ]] there is no change in the reactorpower level as a result of the MELLLA+ operating domain expansion.
For NMP2, there are noincreases in the reactor operating pressure or MS flow rates. The numerical values showing noincreases in the reactor operating pressure and MS flow rates are presented in Table 1-2.Therefore, MELLLA+ operating domain expansion does not affect the NMP2 turbine steambypass system, and no further evaluation is required.
7.4 FEEDWATER AND CONDENSATE SYSTEMSThe FW and condensate systems provide the source of makeup water to the reactor to supportnormal plant operation.
The topics addressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultFeedwater and Condensate Systems[[]] there is no change in the FW pressure, temperature, or flow for the MELLLA+ operating 7-2 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)domain expansion.
The performance requirements for the FW and condensate systems are notchanged by MELLLA+ operating domain expansion, and no further evaluation is required.
[[ ]] there is no change in the NMP2FW pressure, temperature, and flow rates. Because FW flow is unchanged in the MELLLA+domain, system resistance and therefore operating pressures in the MELLLA+ operating domainare not changed.
The numerical values showing no increases in FW temperature and flow ratesare presented in Table 1-2. Therefore, MELLLA+ operating domain expansion does not affectthe NMP2 FW and condensate
: systems, and no further evaluation is required.
[[7-3 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)8.0 RADWASTE SYSTEMS AND RADIATION SOURCESThis section addresses the evaluations that are applicable to MELLLA+.8.1 LIQUID AND SOLID WASTE MANAGEMENT The Liquid radwaste system collects,
: monitors, processes, stores and returns processed radioactive waste to the plant for reuse or discharge.
The topics addressed in this evaluation are:Topic M+LTR Disposition I NMP2 ResultCoolant Fission and Corrosion Product LevelsWaste Volumes8.1.1 Coolant Fission and Corrosion Product LevelsA discussion of the coolant activation products as well as fission and activated corrosion products levels in the coolant is presented in Section 8.4.8.1.2 Waste VolumesR]] becausethe power level, FW flow, and steam flow do not change for the MELLLA+ operating domainexpansion, the volume of liquid radwaste and the coolant concentrations of fission and corrosion products will be unchanged.
The largest source of liquid and wet solid waste is from thebackwash of the condensate demineralizers.
Although the volume of waste generated is notexpected to increase, potentially higher MCO in the reactor steam could result in slightly higherloading on the condensate demineralizers.
Because the higher moisture content will occurinfrequently, the MELLLA+ operating domain expansion will not cause the condensate demineralizer backwash frequency to be changed significantly.
The RWCU filter demineralizer backwash frequency is not affected, as discussed in Section 3.11. Therefore, the waste volumeswill not be affected by the MELLLA+ operating domain expansion, and no further evaluation ofthis topic is required.
[[ ]] there is no change in the reactorpower level as a result of MELLLA+ operating domain expansion.
For NMP2, there are noincreases in the MS or FW flow rates. The numerical values showing no increases in MS andFW flow rates are presented in Table 1-2. The NMP2 MCO will be monitored and controlled to< 0.25 wt.% within the analytical assumption of 0.35 wt.% used in the determination of post-shutdown radiation levels.[[I8.2 GASEOUS WASTE MANAGEMENT The primary function of the gaseous waste management (offgas) system is to process and controlthe release of gaseous radioactive effluents to the site environs so that the total radiation exposure of persons in off-site areas is as low as reasonably achievable (ALARA) and does notexceed applicable guidelines.
The topics addressed in this evaluation are:8-1 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Topic M+LTR Disposition NMP2 ResultOff-Site Release RateRecombiner Performance 8.2.1 Off-Site Release Rate[[ ]]theradiological release rate is administratively controlled to remain within existing limits and is afunction of fuel cladding performance, main condenser air inleakage, charcoal adsorber inlet dewpoint, and charcoal adsorber temperature.
[]] No further evaluation of this topic is required.
]] the NMP2 radiological releaserate is administratively controlled to remain within existing release rate limits. In addition, noneof the applicable identified parameters are affected by MELLLA+ operating domain expansion.
There is no change to the offgas system. Therefore, it can be concluded that the genericdiscussion in the M+LTR is applicable to NMP2. [[]], and no further evaluation isrequired.
[[8.2.2 Recombiner Performance Er]] Therefore, recombiner performance is unaffected by the MELLLA+ operating domain expansion, and no further evaluation is required.
Er ]] the NMP2 radiolytic gas flow rate,the catalytic recombiner temperature, and the offgas condenser heat load, as well as components downstream of the offgas condenser does not change as a result of MELLLA+ operating domainexpansion.
Therefore, the NMP2 recombiner performance is unaffected by the MELLLA+operating domain expansion, and no further evaluation is required.
Er]]8-2 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)8.3 RADIATION SOURCES IN THE REACTOR COREDuring power operation, the radiation sources in the core are directly related to the fission rate.These sources include radiation from the fission process, accumulated fission products, andneutron activation reactions.
The topics addressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultPost-Operational Radiation Sources forRadiological and Shielding Analysis]] the post-operation radiation sources inthe core are primarily the result of accumulated fission products.
[[]] Therefore, no further evaluation ofradiation sources in the reactor core is required.
[[ ]] the reactor power does notincrease as a result of MELLLA+ operating domain expansion.
NMP2 core average exposure isNo further evaluation of radiation sources in the reactor core is required.
8.4 RADIATION SOURCES IN REACTOR COOLANTRadiation sources in the reactor coolant include activation
: products, activation corrosion
: products, and fission products.
The topics addressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultCoolant Activation Products
[[Fission and Activated Corrosion Products8.4.1 Coolant Activation Products[[]] during reactor operation, the coolant passing through the core region becomesradioactive as a result of nuclear reactions.
The coolant activation process is the dominantsource resulting in the production of short-lived radionuclides of N-16 and other activation products.
These coolant activation products are the primary source of radiation in the turbinesduring operation.
The M+LTR states that if [[]] no further evaluation of this topic is required.
]] the reactor power does notincrease as a result of MELLLA+ operating domain expansion.
The NMP2 steam flow rate does8-3 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)not change as a result of MELLLA+ operating domain expansion.
Numerical valuesdemonstrating that the MS flow does not increase are provided in Table 1-2. [[]] No further evaluation of this topic is required.
[[I8.4.2 Fission and Activated Corrosion ProductsThe reactor coolant contains fission products and activated corrosion products.
For theMELLLA+ operating domain, there is no change in the FW flow, steam flow, or power.However,
[[For NMP2, reactor power does not change as a result of the MELLLA+ operating domainexpansion.
The NMP2 MS and FW flow rates do not change as a result of the MELLLA+operating domain expansion.
Numerical values demonstrating that the MS and FW flow rates donot increase are provided in Table 1-2. Therefore, the MELLLA+ operating domain expansion does not affect the total activity concentration in the reactor coolant.Steam separator and dryer performance for MELLLA+ operation is discussed in Section 3.3.3.The moisture content of the MS leaving the vessel is assumed to increase up to 0.35 wt.% attimes while operating near the minimum CF in the MELLLA+ operating domain. Thedistribution of the fission and activated corrosion product activity between the reactor water andsteam is affected by the increased moisture content.
With increased MCO, additional activity iscarried over from the reactor water with the steam. For NMP2, certain individual activation product concentrations were observed to exceed design basis levels at 0.35 wt.% moisturecontent.
: However, total activation product activity was below 30% of the total design basisactivation product activity for water and below 95% of the total design basis activation productactivity for steam. There are no individual design basis requirements for individual activation products.
No fission product concentrations exceeded the design basis.8.5 RADIATION LEVELSRadiation levels during operation are derived from coolant sources.
The topics addressed in thisevaluation are:Topic M+LTR Disposition NMP2 ResultNormal Operational Radiation Levels [_Post-Shutdown Radiation LevelsPost-Accident Radiation Levels ]]8-4 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)8.5.1 Normal Operational Radiation LevelsThe M+LTR describes that plant radiation levels for normal and post-shutdown operation aredirectly dependent upon radiation levels and radionuclide species in the reactor coolant (steamand water) except where the core is directly involved.
[[]]For NMP2, reactor power does not change as a result of the MELLLA+ operating domainexpansion.
The NMP2 MS flow rate does not change as a result of the MELLLA+ operating domain expansion.
Numerical values demonstrating the MS flow rate does not increase areprovided in Table 1-2. Because there is no change in power or steam flow rate for theMELLLA+ expanded operating domain, the radiation levels from the coolant activation productsdo not vary significantly.
As discussed in Section 8.4, the moisture content of the MS leavingthe vessel may increase at certain times while operating in the MELLLA+ operating domain.However, the NMP2 MCO will be monitored and controlled to < 0.25 wt.% within the analytical assumption of 0.35 wt.% used in the determination of normal operation radiation levels. Theoverall radiological effect of the increased moisture content is a function of the plant waterradiochemistry and the levels of activated corrosion products maintained.
NMP2 maintains appropriate health physics and ALARA controls to address any increase in the normal operation levels.8.5.2 Post-Shutdown Radiation LevelsThe M+LTR describes that plant radiation levels for normal and post-shutdown operation aredirectly dependent upon radiation levels and radionuclide species in the reactor coolant (steamand water) except where the core is directly involved.
[[]]For NMP2, reactor power does not change as a result of the MELLLA+ operating domainexpansion.
The NMP2 MS flow rate does not change as a result of the MELLLA+ operating domain expansion.
Numerical values demonstrating the MS flow rate does not increase areprovided in Table 1-2. The shutdown radiation levels are dominated by the accumulated contamination of some fission and activated corrosion products.
As discussed in Section 8.4, themoisture content of the MS leaving the vessel may increase at certain times while operating inthe MELLLA+ operating domain. However, the NMP2 MCO will be monitored and controlled to < 0.25 wt.% within the analytical assumption of 0.35 wt.% used in the determination ofpost-shutdown radiation levels. The overall radiological effect of the increased moisture contentis a function of the plant water radiochemistry and the levels of activated corrosion productsmaintained.
NMP2 maintains appropriate health physics and ALARA controls to address anyincrease in the shutdown radiation levels.8-5 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)8.5.3 Post-Accident Radiation LevelsThe M+LTR describes that the post-accident radiation levels depend primarily upon the coreinventory of fission products and TS levels of radionuclides in the coolant, neither of which isaffected by MELLLA+.
[[]] Section 9.2 discusses DBA radiological consequences.
8.6 NORMAL OPERATION OFF-SITE DOSESThe primary source of normal operation off-site doses is: (1) airborne releases from the offgassystem; and (2) gamma shine from the plant turbines.
The topics addressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultPlant Gaseous Emissions
[[Gamma Shine from the Turbine8.6.1 Plant Gaseous Emissions for the MELLLA+ operating domain expansion, there is no change in the core power and thesteam flow rate. [[ ]] Nofurther evaluation of plant gaseous emissions is required.
Er ]] the reactor power does not changeas a result of the MELLLA+ operating domain expansion.
The NMP2 steam flow rate does notchange as a result of the MELLLA+ operating domain expansion.
Numerical valuesdemonstrating that the MS flow does not increase are provided in Table 1-2. [[]] Therefore, no further evaluation of plant gaseous emissions is required.
8.6.2 Gamma Shine from the Turbine]] Provided these conditions are met, no further evaluation of gamma shine fromthe turbine is required.
[[ ]] and as discussed in Section 3.2.1,the change in flux as a result of the MELLLA+ operating domain expansion is insignificant.
TheNMP2 steam flow rate does not change as a result of the MELLLA+ operating domainexpansion.
Numerical values demonstrating the MS flow does not increase are provided in8-6 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Table 1-2. [[8-7 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)9.0 REACTOR SAFETY PERFORMANCE EVALUATIONS This section addresses the evaluations that are applicable to MELLLA+.9.1 ANTICIPATED OPERATIONAL OCCURRENCES The NMP2 USAR defines the licensing basis AOOs. Table 9-1 of the M+LTR provides anassessment of the effect of the MELLLA+ operating domain expansion on each of theReference 4 limiting AOO events and key non-limiting events. Table 9-1 of the M+LTRincludes fuel thermal margin, overpressure, and loss of water level events. The overpressure protection analysis events are addressed in Section 3.1. The topics addressed in this evaluation are as follows:Topic M+LTR Disposition NMP2 ResultFuel Thermal Margin Events [[Power and Flow Dependent LimitsNon-Limiting Events ]]9.1.1 Fuel Thermal Margin Events[[i]] The limiting thermal margin events definedin Reference 4 include:* Generator Load Rejection Without Bypass (LRNBP) or Turbine Trip Without Bypass(TTNBP),* Loss of Feedwater Heating (LFWH)," RWE, and* Feedwater Controller Failure (Maximum Demand) (FWCF).The fuel loading error is categorized as an Infrequent Incident.
: However, if the licensee does notmeet the requirements of GESTAR II (Reference 4), the fuel loading error event would beanalyzed as an AOO. NMP2 does not meet the requirements of Reference
: 4. Therefore, the fuelloading error event is evaluated as an AOO for each reload. [[9-1 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)]]The thermal margin event analysis is performed as part of the reload process for each reload coreand results are documented in the SRLR. From M+LTR SER Limitation and Condition 12.4,]] Inaccordance with Methods LTR SER Limitation and Condition 9.19, an additional 0.01 will beadded to the OLMCPR for conditions above the stretch power uprate power level or above theMELLLA boundary (MELLLA+
conditions),
until such time that GEH expands the experimental database supporting the Findlay-Dix void-quality correlation to demonstrate the accuracy andperformance of the void-quality correlation based on experimental data representative of thecurrent fuel designs and operating conditions during steady-state, transient, and accidentconditions.
In the event that the cycle-specific reload analysis is based on TRACG rather thanODYN for AOO, no 0.01 adder to the OLMCPR is required.
In accordance with M+LTR SER Limitation and Condition 12.16, an RWE analysis wasperformed to confirm the adequacy of the generic RBM setpoints.
The RWE was simulated using the three-dimensional core simulator PANACEA.
The analysis was performed with anapproximate equilibrium core at the MELLLA+ 100% power, 85% CF statepoint for acomprehensive set of RBM setpoints.
The results of this RWE analysis confirmed the validity ofthe generic RBM setpoints.
The RWE results also meet the 1% cladding circumferential plasticstrain acceptance criterion.
In accordance with Methods LTR SER Limitations and Conditions 9.9, 9.10, and 9.11,acceptable fuel rod T-M performance for both U02 and GdO2 fuel rods was demonstrated.
Results for all AOO pressurization transient events analyzed, including EOOS, showed at least10% margin to the fuel centerline melt and the 1% cladding circumferential plastic strainacceptance criteria.
The minimum calculated margin to the fuel centerline melt criterion forAOO pressurization transient events was 19.2%. The minimum calculated margin to thecladding strain criterion was 18.2%. Fuel rod T-M performance will be evaluated as part of theRLAs performed for the cycle-specific core. Documentation of acceptable fuel rod T-Mresponse will be included in the SRLR or COLR.9-2 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)9.1.2 Power and Flow Dependent LimitsThe operating MCPR., LHGR, and/or MAPLHGR thermal limits are modified by a flow factorwhen the plant is operating at less than 100% CF. The MCPR flow factor (MCPRf) and theLHGR flow factor (LHGRFACf) are primarily based upon an evaluation of the slowrecirculation flow increase event. [[]] Table 9-2 summarizes the results of the slowrecirculation flow increase analysis and compares them with the MCPR flow limit. Thereference limits bound the slow recirculation flow results performed for the MELLLA+operating domain. [[Similarly, the thermal limits are modified by a power factor (MCPRp) when the plant is operating at less than 100% power. [[1]]9.1.3 Non-Limiting Events[[E ]] provides anassessment of the effect of the MELLLA+ operating range expansion for each of the Reference 4limiting AOO events and key non-limiting events. Provided these evaluations are applicable toNMP2, no further evaluations are required for non-limiting events. The results of the M+LTRassessment are presented in the table below:Event Discussion Fuel Thermal Margin EventsInadvertent HPCI Start The inadvertent HPCI start event is not applicable for NMP2.Slow Recirculation Increase(Kf, MCPRf) (Reference 4 event -bounds recirculation event AOOs)Fast Recirculation Increase9-3 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)1]9.2 DESIGN BASIS ACCIDENTS AND EVENTS OF RADIOLOGICAL CONSEQUENCE 9.2.1 Design Basis EventsThis section addresses the radiological consequences of a DBA.evaluation are:The topics addressed in thisTopic M+LTR Disposition NMP2 ResultControl Rod Drop Accident
[[Instrument Line Break Accident (ILBA)Main Steam Line Break Accident(MSLBA) (Outside Containment)
Loss-of-Coolant Accident(Inside Containment)
Large Line Break(Feedwater or Reactor Water Cleanup)Liquid Radwaste Tank FailureFuel Handling Accident (FHA)Offgas System FailureCask Drop9.2.1.1 Control Rod Drop Accident[[ ]] the radiological consequences of this DBA are evaluated to determine off-site doses as well as control roomoperator doses. DBA calculations are generally based on core inventory sources or TS sourceterms, [R]] ForEvent 1, the source term is based on fission products from failed fuel and the instantaneous transport to the condenser remains conservative for MELLLA+,
therefore Event 1 is unchanged for MELLLA+.
The source term for Event 2 is based on the maximum activity allowed underthe MSL radiation monitor safety limit, therefore the analyzed condition in Event 2 is boundingfor MELLLA+.The CRDA release is dependent on the source terms and maximum peaking factor. Operation inthe MELLLA+ operating domain does not affect the alternate source term (AST) CRDA source9-4 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)term and the peaking factor remains bounding.
[[]] and no further evaluation is required.
9.2.1.2 Instrument Line Break Accident[[ ]] the radiological consequences of a DBA are evaluated to determine off-site doses as well as control roomoperator doses. DBA calculations are generally based upon core inventory sources or TS sourceterms, [[]] Table 9-4 of the M+LTR provides a detailedevaluation of each of the above events. [[]] then no furtherreview is required.
Therefore the ILBA evaluation is not affected by the MELLLA+ operating domain expansion and no further evaluation is required.
9.2.1.3 Main Steam Line Break Accident (Outside Containment)
]] the radiological consequences of this DBA are evaluated to determine off-site doses aswell as control room operator doses. DBA calculations are generally based on core inventory sources or TS source terms, [[]] Table 9-4 of the9-5 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)M+LTR provides a detailed evaluation of the MSLBA events. [[]] then no further review is required.
]] In addition, the analysis of record for the worst-case MSLBA radiological consequences is at hot standby conditions, which is outside of the MELLLA+ operating domain.Therefore the NMP2 MSLBA evaluation is not affected by the MELLLA+ operating domainexpansion and no further evaluation is required.
9.2.1.4 Loss-of-Coolant Accident (Inside Containment)
[[]]the radiological consequences of this DBA are evaluated to determine off-site doses aswell as control room operator doses. DBA calculations are generally based on core inventory sources or TS source terms, [[The design input and assumptions for suppression pool pH were previously evaluated.
Thesource term assumptions are not changing for MELLLA+.
In addition, the acid production termsare not changing for MELLLA+ conditions.
The use of Sodium Pentaborate as a buffer perUSAR Section 15.8.3.5 continues to be appropriate.
Table 9-4 of the M+LTR provides a detailed evaluation of each of the above events. [[]] then no further review is required.
9-6 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)]] Therefore, theNMP2 LOCA evaluation is not affected by the MELLLA+ operating domain expansion and nofurther evaluation is required.
9.2.1.5 Feedwater Line BreakE[ ]] the radiological consequences of a DBA are evaluated to determine off-site doses as well as control roomoperator doses. DBA calculations are generally based upon core inventory sources or TS sourceterms, [[]] Table 9-4 of the M+LTR provides a detailedevaluation of each of the above events. [[]] then no furtherreview is required.
]] Therefore the NMP2 FW Line Break evaluation isnot affected by the MELLLA+ operating domain expansion and no further evaluation is required.
[[9.2.1.6 Liquid Radwaste Tank FailureThe M+LTR discussion of the liquid radwaste tank failure describes in Table 9-4 of the M+LTREr9-7 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)]] The moisture content of the MS increases in a smallarea of the MELLLA+ operating domain near the minimum CF and 100% CLTP (seeSections 3.3.4 and 8.4). Section 8.5 discusses the analysis of the radioactive nuclide inventory inthe radwaste tank. [[]] Therefore, the liquid radwaste tank failure accident does not present a radiological concern at NMP2 for operation in the MELLLA+ operating domain.Er9.2.1.7 Fuel Handling AccidentE[ r]the radiological consequences of this DBA are evaluated to determine off-site doses as well ascontrol room operator doses. DBA calculations are generally based on core inventory sources orTS source terms, [[]] Table 9-4 of the M+LTRprovides a detailed evaluation of each of the above events. [[]]then no further review is required.
ErTherefore, the NMP2 FHA evaluation for the MELLLA+ operating domain is bounded by theanalysis for the current licensed operating domain, and no further evaluation is required.
Er1]9.2.1.8 Offgas System FailureEr ]] theradiological consequences of a DBA are evaluated to determine off-site doses as well as controlroom operator doses. DBA calculations are generally based upon core inventory sources or TSsource terms, E[]] Table 9-4 of the M+LTR provides a9-8 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)detailed evaluation of each of the above events. [[]] then no furtherreview is required.
]] Therefore the NMP2 offgas systemfailure evaluation is not affected by the MELLLA+ operating domain expansion and no furtherevaluation is required.
1]]9.2.1.9 Cask Drop[[ ]] the radiological consequences of a DBA are evaluated to determine off-site doses as well as control roomoperator doses. DBA calculations are generally based upon core inventory sources or TS sourceterms, [[]] Table 9-4 of the M+LTR provides a detailedevaluation of each of the above events. [[]] then no furtherreview is required.
]] Therefore the NMP2 cask drop evaluation for the MELLLA+ operating domain is bounded by the analysis for the current licensed operating domain, and no furtherevaluation is required.
[[I9.2.2 Other Events with Radiological Consequences This section addresses the radiological consequences of other events as described in the M+LTR.The topics addressed in this evaluation are:Topic M+LTR Disposition I NMP2 ResultNone N/A9-9 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)9.3 SPECIAL EVENTSThis section considers three special events: ATWS, SBO, and ATWS with Core Instability.
Theoperator actions required as a result of ATWS are reviewed and discussed as a part ofSection 10.9. The topics addressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultATWS (Overpressure)
[[ATWS (Suppression Pool Temperature and Containment Pressure)
ATWS (Peak Cladding Temperature and Oxidation)
Station BlackoutATWS with Core Instability 9.3.1 Anticipated Transients Without ScramThere is no change in core power, decay heat, pressure, or steam flow as a result of theMELLLA+ operating range expansion.
[[]] The ATWS evaluation acceptance criteria are to:* Maintain reactor vessel integrity (i.e., peak vessel bottom pressure less than the ASMEService Level C limit of 1,500 psig)" Maintain containment integrity (i.e., maximum containment pressure lower than thedesign pressure of the containment structure and maximum suppression pool temperature lower than the pool temperature limit)* Maintain coolable core geometryPlant-specific ATWS analyses are performed to demonstrate that the ATWS acceptance criteriaare met for operation in the MELLLA+ operating domain. NMP2 meets the ATWS mitigation requirements in 10 CFR 50.62 for an alternate rod insertion (ARI) system, SLS boron injection equivalent to 86 gpm, and automatic RPT logic (i.e., ATWS-RPT).
The plant-specific ATWSanalyses take credit for the ATWS-RPT and SLS. However, ARI is not credited.
In accordance with M+LTR SER Limitations and Conditions 12.18.e and 12.18.f, the key inputparameters to the plant-specific ATWS analyses are provided in Table 9-3. For key inputparameters that are important to simulating the ATWS analysis and are specified in the TS(e.g., SLS parameters and ATWS-RPT),
the calculation assumptions are consistent with theallowed NMP2 TS values and plant configuration.
Although conservative inputs consistent withthe NMP2 TS values were used, this does not imply that ATWS is part of the TS Bases. In someinstances, nominal input parameters are used consistent with the approach in Reference 38.Reference 38 contained sensitivity studies on key parameters for information.
: However, therewas no specific uncertainty treatment applied.
In addition, the EOOS assumptions for ATWS areconsistent with TS requirements.
M+LTR SER Limitation and Condition 12.23.2 requires thatthe plant-specific automatic settings be modeled for ATWS. For NMP2, the plant automatic 9-10 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)settings, which include the ATWS-RPT, low pressure isolation, and SRV actuation, are modeledbased on the input parameters in Table 9-3. As required by M+LTR SER Limitation andCondition 12.23.8, the plant-specific ATWS analyses account for plant- and fuel-design-specific features including debris filters.9.3.1.1 Anticipated Transients Without Scram (Licensing Basis)The plant-specific ATWS analysis is performed using the approved ODYN methodology documented in Section 5.3.4 of ELTRI (Reference 5). The ATWS analysis using the ODYNmethodology is the plant's licensing basis for this application.
A licensing basis ODYN ATWS analysis was performed to demonstrate the effect of MELLLA+on the ATWS acceptance criteria.
[[The results of the licensing basis ODYN ATWS analysis are provided in Tables 9-4 and 9-5.The tabulated peak value and time trace for reactor power, reactor dome pressure, PCT andsuppression pool temperature is provided in Table 9-5 for the limiting event in the ODYNATWS analysis.
For reactor power, analysis results are provided for the limiting event withrespect to peak reactor vessel pressure.
The limiting event is the PRFO at EOC.]] The peak vessel bottom pressure response is dependent on several inputs,including the SRV upper tolerances assumed in the ATWS analysis.
In accordance with M+LTRSER Limitation and Condition 12.23.3,
[[9-11 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)]] NMP2 as-found SRV lift setpoint tests do not show a propensity for setpoint drifthigher than the 3% drift tolerance.
Therefore, the SRV upper tolerances used in the ATWSanalysis are consistent with the plant-specific performance.
The suppression pool temperature following an ATWS is bounded by EPU. Therefore, MELLLA+ does not affect the NPSH available for the ECCS pumps. [[]] M+LTR SERLimitation and Condition 12.23.11 requires that the use of suppression pool temperature limitshigher than the heat capacity temperature limit (HCTL) for emergency depressurization must bejustified.
The containment design limit is the ATWS acceptance criteria.
[[]] Per M+LTRSER Limitation and Condition 12.18.b, a best estimate TRACG analysis modeling emergency depressurization is not required if the plant increases boron-10 concentration/enrichment so thatthe integrated heat load to containment calculated by the licensing ODYN calculation does notchange with respect to a reference OLTP / 75% flow ODYN calculation.
The peak containment pressure is 6.5 psig, which is below the NMP2 design limit of 45 psig. Inaccordance with M+LTR SER Limitation and Condition 12.23.10, the increase in containment pressure resulting from ATWS events with MELLLA+ operation does not adversely affectoperation of the safety-grade equipment.
As discussed in Sections 4.2.6 and 10.3, safety-grade equipment has been evaluated for operation at DBA LOCA conditions; these conditions boundthe containment pressure increase following an ATWS event. Therefore, operation of safety-grade equipment is not adversely affected by the MELLLA+ operating domain expansion.
A coolable core geometry is ensured by meeting the 2,200'F PCT and 17% local claddingoxidation acceptance criteria of 10 CFR 50.46. [[]]The results of the licensing basis ODYN ATWS analysis meet the ATWS acceptance criteria.
Therefore, the NMP2 response to an ATWS event initiated in the MELLLA+ operating domainis acceptable.
9-12 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)9.3.1.1.1 Anticipated Transients Without Scram (Single SLS Pump)An additional plant-specific ATWS analysis is performed using the same approved ODYNmethodology as the licensing basis calculation.
The purpose of the additional analysis is to showthat all ATWS acceptance criteria are met with only a single SLS pump operating.
Inputparameters specific to this analysis are provided in Table 9-6. All other input parameters areconsistent with Table 9-3.The results of the single SLS pump ODYN ATWS analysis are provided in Tables 9-7 and 9-8.The tabulated peak value and time trace for reactor power, reactor dome pressure, PCT, andsuppression pool temperature is provided in Table 9-8 for the limiting event in the ODYNATWS analysis.
For reactor power, analysis results are provided for the limiting event withrespect to peak reactor vessel pressure.
The limiting event is the PRFO at EOC.All ATWS acceptance criteria are met at MELLLA+ conditions with only a single SLS pumpoperating.
9.3.1.2 Anticipated Transients Without Scram (Best-Estimate Calculation)
The HCTL is provided in the NMP2 EOPs. The HCTL is a function of operating reactorpressure and suppression pool water level. For normal suppression pool water level, the HCTLis approximately 140'F near the SRV opening pressure.
At the extreme upper suppression poolwater level covered by EOPs, the HCTL is approximately 90'F near the SRV opening pressure.
NMP2 EOPs require depressurization during an ATWS event when the suppression pooltemperature reaches the HCTL. As a result, M+LTR SER Limitation and Condition 12.18.arequires that a best-estimate TRACG ATWS analysis must be performed for NMP2 because hotshutdown was not achieved prior to reaching the HCTL based on the licensing basis ODYNcalculation.
M+LTR SER Limitation and Condition 12.18.c further requires that PCT beevaluated for both the initial overpressure and depressurization phases for the TRACG ATWScalculation.
: However, M+LTR SER Limitation and Condition 12.18.b states that the TRACGcalculation is not required if the plant increases the boron-10 concentration/enrichment so thatthe integrated heat load to containment calculated by the licensing ODYN calculation does notchange with respect to a reference OLTP/75%
flow ODYN calculation.
For NMP2, the boron-10 enrichment is increased from 25 atom % to 92 atom % at MELLLA+operating conditions.
The results of the MELLLA+ licensing ODYN calculation are comparedto a reference OLTP/75%
flow ODYN calculation.
[[9-13 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)]]As a result of the increased boron-10 enrichment at MELLLA+,
the best-estimate TRACGATWS analysis is not required to meet the ATWS acceptance criteria.
9.3.2 Station Blackout[[ ]] there is nosignificant change in core power, decay heat, pressure, or steam flow as a result of theMELLLA+ operating domain expansion.
[[]] there is no change in the reactorpower level as a result of the MELLLA+ operating domain expansion.
As discussed inSection 1.2.3, there is no significant change in decay heat as a result of the MELLLA+ operating domain expansion.
For NMP2, there are no increases in reactor operating pressure as result ofMELLLA+ operating domain expansion.
For NMP2, there are no significant changes in the MSflow rate. The numerical values showing no significant changes to reactor operating power andMS flow rate are presented in Table 1-2. [[]] No furtherevaluation is required.
9.3.3 ATWS with Core Instability The NRC has reviewed and accepted GEH's disposition of the effect of large coupled thermal-hydraulic/neutronic core oscillations during a postulated ATWS event, which is presented inNEDO-32047-A (Reference 39). The companion report, NEDO-32164 (Reference
: 40) wasapproved by the same NRC SER. The NRC review concluded that the GEH TRACG code is anadequate tool to estimate the behavior of operating reactors during transients that may result inlarge power oscillations.
The review also concluded that ATWS criteria, which are listed below,were met:1. Radiological consequences must be maintained within 10 CFR 100 guidelines;
: 2. Primary system integrity to be maintained;
: 3. Fuel damage limited so as not to significantly distort the core, impede core cooling, orprevent safe shutdown;
: 4. Containment integrity to be maintained; and5. Long-term shutdown and cooling capability to be maintained.
Furthermore, the NRC review concluded that the specified operator actions are sufficient tomitigate the consequences of an ATWS event with large core power oscillations.
[[9-14 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)]]M+LTR SER Limitation and Condition 12.19 requires that a plant-specific ATWS instability calculation be performed to demonstrate that NMP2 EOP actions, including boron injection andwater level control strategy, effectively mitigate an ATWS event with large power oscillations inthe MELLLA+ operating domain. The plant-specific ATWS instability calculation was(1) based on the limiting of BOC, peak reactivity exposure condition (MOC), and EOC;(2) modeled the plant-specific configuration important to the ATWS instability response; and(3) used the limiting of the regional mode or core-wide mode nodalization scheme. M+LTRSER Limitation and Condition 12.23.5 requires that the power density be less than52.5 MWt/Mlbm/hr.
For NMP2, the plant-specific maximum power-to-flow ratio at rated powerand minimum CF is 43.3 MWt/Mlbm/hr and meets the requirement.
The plant-specific TRACGcalculation modeled in-channel water rod flow in accordance with M+LTR SER Limitation andCondition 12.24.1.
The plant-specific ATWS instability calculation was performed using thelatest NRC-approved neutronic and thermal-hydraulic codes TGBLA06/PANAC 11 andTRACG04 (Reference 41).9-15 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)The results of the plant-specific TRACG ATWS instability calculation are provided in Table 9-9.Figures 9-9, 9-10, 9-11, and 9-12 show the mitigating effect of decreasing water level and boroninjection on the core and bundle response to both the TTWBP (for limiting pressure) and RPT(for limiting PCT) ATWS instability events.The results of the plant-specific TRACG ATWS instability calculation meet the ATWSacceptance criteria.
Therefore, the NMP2 response to an ATWS with core instability eventinitiated in the MELLLA+ operating domain is acceptable.
NMP2 EOP actions, including boroninjection and water level control strategy, effectively mitigate an ATWS event with large poweroscillations in the MELLLA+ operating domain.9-16 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Table 9-1 AOO Event Results SummaryFlow Peak Dome Peak Vessel Peak Neutron Peak Heat GE14(% of Rated) Event Pressure Pressure Flux Flux(psig) (psig) (%) (%Initial)
ACPR (')105 LRNBP 1,255 1,283 520 133 0.3085 LRNBP 1,253 1,275 402 125 0.26105 TTNBP 1,253 1,280 511 130 0.3085 TTNBP 1,251 1,273 367 122 0.25105 FWCF 1,229 1,257 474 131 0.2885 FWCF 1,228 1,249 338 123 0.2385 LFWH (2) -(3) -(3) -(3) -(3) 0.14100 RWE _ (3) _ (3) _ (3) _ (3) 0.2985 RWE _ (3) _ (3) _ (3) -(3) 0.29Notes:(1) For the pressurization events, the uncorrected ACPR values are presented.
(2) The LFWH is most limiting at low CF, and therefore, it was not analyzed at CLTP/MELLLA conditions.
The event is non-limiting with respect to ACPR.(3) The PANACEA code is used to analyze slow events; therefore, system response parameters are notapplicable.
9-17 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Table 9-2 Comparison of Slow Recirculation Flow Increase Results and MCPR FlowLimitFlow (%) Slow Recirculation Flow MCPR Flow LimitIncrease MCPR112 1.13 1.25110 1.14 1.25100 1.17 1.2590 1.21 1.2580 1.25 1.3070 1.29 1.3760 1.32 1.4555 1.34 1.489-18 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Table 9-3 Key Input Parameters for ATWS AnalysesParameter CLTP MELLLA+ BasisReactor Power (MWt) 3,988 3,988Analyzed Power (MWt) 3,988 3,988Analyzed Core Flow (Mlbm/hr
/ % Rated) 107.4 / 99.0 92.2 / 85.0Reactor Dome Pressure (psia) 1,035 1,035MSIV Closure Time (sec) 4.0 4.0High Pressure ATWS-RPT Setpoint (psig) 1,095.0 1,095.0Low Pressure Isolation Setpoint (psig) 720.0 720.0RCIC Flow Rate (gpm) 600.0 600.0Number of SRVs / SRVOOS 18/2 18/2Each SRV Capacity at 1,145 psig (lbm/hr) 890,371 890,371SRV Analytical Opening Setpoints (psig) 1,121 -1,161 1,121 -1,161SLS Injection Location HPCS HPCSSLS Injection Rate (gpm) 82.4 80.01Boron-10 Enrichment (atom %) 25.0 92.0Sodium Pentaborate Concentration
(% by Weight) 13.6 13.6SLS Liquid Transport Time (sec) 120.0 124.0'Initial Suppression Pool Liquid Volume (ft3) 145,200 145,200Initial Suppression Pool Temperature
(&deg;F) 90.0 90.0Number of RHR Suppression Pool Cooling Loops 2 2RHR Heat Exchanger Effectiveness Per Loop 249.0 265.02(BTU/sec-&deg;F)
RHR Heat Exchanger Effectiveness Per Loop 249.0 265.02during LOOP Event (BTU/sec-&deg;F)
RHR Service Water Temperature
('F) 84.0 84.0Notes:1. [[2. This value is consistent with the EPU LOCA long-term suppression pool temperature analysis.
9-19 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Table 9-4 Key Results for Licensing Basis ODYN ATWS AnalysisATWS Acceptance Criteria CLTP MELLLA+ Design LimitPeak Vessel Pressure (psig) [[ _1,500Peak Suppression Pool Temperature
('F) 190Peak Containment Pressure (psig) 45.0Peak Cladding Temperature
('F) 2,200Peak Local Cladding Oxidation
(%) 2 17Peak Upper Plenum Pressure After SLSPump Startup (psia) ]]_--Notes:1. [[]]9-20 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Table 9-5 ODYN ATWS Analysis Limiting Event Results at MELLLA+Parameter Limiting Event Peak Value Time TraceReactor Power (Neutron Flux) PRFO at EOC 968% Rated Figure 9-3Reactor Dome Pressure PRFO at EOC 1,370 psia Figure 9-3Suppression Pool Temperature MSIVC at EOC 160&deg;F Figure 9-4Peak Cladding Temperature PRFO at EOC 1,437&deg;F Figure 9-59-21 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Table 9-6 Key Input Parameters for Single SLS Pump ATWS AnalysesParameter MELLLA+ BasisSLS Injection Rate (gpm) 40.0 ' [[SLS Liquid Transport Time (sec) 236.0'Notes:1. [[9-22 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Table 9-7 Key Results for Single SLS Pump ODYN ATWS AnalysisATWS Acceptance Criteria MELLLA+ Design LimitPeak Vessel Pressure (psig) 1,500Peak Suppression Pool Temperature
(&deg;F) 190Peak Containment Pressure (psig) 45.0Peak Cladding Temperature (0F) 2,200Peak Local Cladding Oxidation
(%) 17Peak Upper Plenum Pressure After SLS Pump Startup (psia) --Notes:1. [[9-23 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Table 9-8 Single SLS Pump ODYN ATWS Analysis Limiting Event ResultsParameter Limiting Event Peak Value Time TraceReactor Power (Neutron Flux) PRFO at EOC 968% Rated Figure 9-6Reactor Dome Pressure PRFO at EOC 1,370 psia Figure 9-6Suppression Pool Temperature MSIVC at EOC 1660F Figure 9-7Peak Cladding Temperature PRFO at EOC 1,437&deg;F Figure 9-89-24 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Table 9-9 Key Results for ATWS with Core Instability Analysis from MELLLA+Operating DomainATWS Acceptance Criteria MELLLA+ Design LimitPeak Vessel Pressure (psig) 1 [[ 1,500Peak Cladding Temperature
(&deg;F) 2,200Peak Local Cladding Oxidation
(%) 2 ]] 17Notes:1. The TRACG calculation of peak vessel pressure is based on two SRVs OOS.2. [[I]9-25 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)275 [ Ne1 Fs HW 55F 70 --- Vessel DomePre..u.
1350--Awerages Surface Heat Film Safety Val'e Flow Core Inlet Flow -- ReliefVale Flow250 500 re- Turbine Btass Steam Flow60 1300225 450200 400 501250175 300S150 40 -1200S125 _250E30 1150100 2002Z75 150 20 1050 10010 105025 500 010 0 N I q i F q 10000 1 2 3 4 5 6 70 1 2 3 4 5 6 7Time (s) Time (5)125 Vese Le 60 10 Void Reactl-A&- Vessel Lream Flow -S- .nram Readlly-S- Feedweter Flow -- Doppler ReactMt"50_G T'urbine Steam Flow Total React"~t75 4050 so25 20~. .S -200 10-25 0-50 4 40 Ia 1 2 3 4 5 6 7 0 1 2 3 4 5 6 7Time (s) Time (s)PID: 50163Figure 9-1 LRNBP at ICF9-26 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)20017515012515025012510075so01251070605040302015013501300125012002~1155011100105010S0Time (s)Time (S)RD:50163Figure 9-2 LRNBP at MELLLA+9-27 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Figure 9-3 ODYN ATWS Analysis
-PRFO at EOC Short-Term Results9-28 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Figure 9-4 ODYN ATWS Analysis
-MSIVC at EOC Long-Term Results9-29 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)[RFigure 9-5 ODYN ATWS Analysis
-PRFO at EOC PCT9-30 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Figure 9-6 Single SLS Pump ODYN ATWS Analysis
-PRFO at EOC Short-Term Results9-31 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)111]Figure 9-7 Single SLS Pump ODYN ATWS Analysis
-MSIVC at EOC Long-Term Results9-32 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Figure 9-8 Single SLS Pump ODYN ATWS Analysis
-PRFO at EOC PCT9-33 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Figure 9-9 ATWS Instability from MELLLA+ Operating Domain -Turbine Trip withFull Bypass9-34 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)]Figure 9-10 ATWS Instability from MELLLA+ Operating Domain -Turbine Trip withFull Bypass9-35 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)I]Figure 9-11 ATWS Instability from MELLLA+ Operating Domain -Recirculation PumpTrip9-36 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)[[IFigure 9-12 ATWS Instability from MELLLA+ Operating Domain -Recirculation PumpTrip9-37 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)10.0 OTHER EVALUATIONS This section addresses the evaluations in Section 10 of the M+LTR.10.1 HIGH ENERGY LINE BREAKHELBs are evaluated for their effects on equipment qualification.
The topics addressed in thisevaluation are:TopicSteam LinesBalance-of-Plant Liquid LinesOther Liquid LinesM+LTR Disposition NMP2 Result1]10.1.1 Steam LinesMELLLA+ operating domain expansion has no effect on the steam pressure or enthalpy at thepostulated steam line break locations.
The MS enthalpy will be slightly lower for MELLLA+and hence the EPU HELB subcompartment analyses are bounding for MELLLA+.
[[]] a review of the heat balancesproduced for NMP2 MELLLA+ operating domain expansion confirms that there is no significant effect on the steam pressure or enthalpy at the postulated break locations (e.g., MS and RCIC).10.1.2 Balance-of-Plant Liquid Lines[[ 1]MELLLA+ operating domain expansion has no effect on the steam pressure or enthalpy at thepostulated FW line break locations.
[[]] a review of the heat balancesproduced for MELLLA+ confirms that there is no effect on the liquid line conditions at thepostulated FW break locations.
[[10-1 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)10.1.3 Other Liquid Lines]] The scope of theseevaluations includes MELLLA+ operating domain expansion effects on subcompartment pressures and temperatures, pipe whip, jet impingement, and flooding, consistent with the plantlicensing basis.[[ ]] a review of the heat balancesproduced for the NMP2 MELLLA+ operating domain confirms that there is no effect on theliquid line conditions (excluding FW addressed in Section 10.1.2) at the postulated breaklocations.
[[]] The scope of these evaluations includes MELLLA+ operating domainexpansion effects on subcompartment pressures and temperatures, pipe whip, jet impingement, and flooding, consistent with the plant licensing basis. [[]]10.2 MODERATE ENERGY LINE BREAKModerate energy line breaks (MELBs) are evaluated for their effects on equipment qualification.
NMP2 uses the MELB equivalent term moderate energy line crack (MELC). The topicsaddressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultFloodingEnvironmental Qualification 10.2.1 Flooding]] a review of the NMP2 auxiliary flowrates and system inventories shows that MELLLA+ operating domain expansion does not affectthe flow rates of moderate energy piping systems.
Also, for NMP2, no operational modesevaluated for MELB are affected by MELLLA+ operating domain expansion.
[[10-2 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)1]10.2.2 MELB Environmental Qualification
]] a review of the NMP2 auxiliary flowrates and system inventories shows that MELLLA+ operating domain expansion does not affectthe flow rates of moderate energy piping systems.
Also, for NMP2, no operational modesevaluated for MELB are affected by MELLLA+ operating domain expansion.
[[10.3 ENVIRONMENTAL QUALIFICATION Safety-related components are required to be qualified for the environment in which theyoperate.
The topics addressed in this evaluation are:TopicElectrical Equipment Mechanical Equipment with Non-Metallic CoMechanical Component Design Oualification M+LTR Disposition NMP2 Result[[I___________
1110.3.1 Electrical Equipment there is no change or increase in core power, radiation levels, decay heat, pressure, steam flow,or FW flow as a result of the MELLLA+ operating domain expansion.
[[]] No further evaluation isrequired for EQ of electrical equipment as a result of MELLLA+ operating domain expansion.
[[ ]] the reactor power does notincrease as a result of MELLLA+ operating domain expansion.
There is no change in normal10-3 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)operation radiation levels (see Section 8.5). There is also no change in decay heat (seeSection 1.2.3). For NMP2, there are no increases in reactor operating
: pressure, MS or FW flowrates. The numerical values showing no increases in reactor operating
: pressure, MS or FW flowrates are presented in Table 1-2. [[]] No further evaluation is required for EQ ofelectrical equipment as a result of MELLLA+ operating domain expansion.
[[10.3.2 Mechanical Equipment With Non-Metallic Components
[r]] operation in the MELLLA+ operating domain does not increaseany of the normal process temperatures.
[[]] No further evaluation is required for EQ of mechanical equipment with non-metallic components as a result of the MELLLA+ operating domain expansion.
[[ ]] for NMP2, normal processtemperatures are not affected by MELLLA+.
[[]] No furtherevaluation is required for EQ of mechanical equipment with non-metallic components as a resultof the MELLLA+ operating domain expansion.
Er10.3.3 Mechanical Component Design Qualification
[[]] operation in the MELLLA+ operating domain does not affect any ofthe normal process temperatures, pressures, or flow rates. [[]] The change in fluidinduced loads on safety-related components is discussed in Sections 3.2.2, 3.5, and 4.1.2. [[10-4 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)]] for NMP2, normal processtemperatures, pressures, and flow rates are not affected by MELLLA+.
There is no change inradiation levels (see Section 8.5). [[10.4 TESTINGWhen the MELLLA+ operating domain expansion is implemented, testing is recommended toconfirm operational performance and control aspects of the MELLLA+ changes.
The topicsaddressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultSteam Separator-Dryer Performance
[[APRM Calibration Core Performance Pressure Regulator Water Level Setpoint ChangesNeutron Flux Noise Surveillance 10.4.1 Steam Separator-Dryer Performance The performance of the steam separator-dryer (i.e., MCO) is determined by a test similar to thatperformed in the original startup test program.
Testing will be performed near the CLTP and theMELLLA+ minimum CF statepoint of 85% as well as other statepoints that may be deemedvaluable for the purpose of defining the MCO magnitude and trend.10.4.2 Average Power Range Monitor Calibration The APRM system is calibrated and functionally tested. The APRM STP scram and rod blockare calibrated with the MELLLA+ equations and the APRM trips and alarms tested. This testwill confirm that the APRM trips, alarms, and rod blocks perform as intended in the MELLLA+operating domain.10.4.3 Core Performance The core performance test will evaluate the core thermal power, fuel thermal margin, and CFperformance to ensure a monitored approach to CLTP in the MELLLA+ operating domain.Measurements of reactor parameters are taken in the MELLLA+ operating domain. Corethermal power and fuel thermal margin are calculated using accepted methods.
Aftersteady-state conditions are established, measurements will be taken, core thermal power and fuelthermal margin calculated, and evaluated against projected values and operational limits.10-5 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)10.4.4 Pressure Regulator The pressure regulator test will confirm that the pressure control system settings established foroperation at CLTP are adequate in the MELLLA+ operating domain. The pressure regulator should not require any changes from the settings established for the current licensed operating domain. The pressure control system response to pressure setpoint changes is determined bymaking a down setpoint step change and, after conditions stabilize, an upward setpoint stepchange.10.4.5 Water Level Setpoint ChangesThe water level setpoint changes test verifies that the FW control system can provide acceptable reactor water level control in the MELLLA+ operating domain. Reactor water level setpoint stepchanges are introduced into the FW control system, while the plant response is monitored.
10.4.6 Neutron Flux Noise Surveillance The neutron flux noise surveillance test verifies that the neutron flux noise level in the reactor iswithin expectations in the MELLLA+ operating domain. The noise will be recorded bymonitoring the LPRMs and APRMs at steady-state conditions in the MELLLA+ operating domain.10.5 INDIVIDUAL PLANT EXAMINATION This section provides an assessment of the risk increase, including core damage frequency (CDF)and large early release frequency (LERF), associated with operation in the MELLLA+ range.The topics addressed in this evaluation are:M+LTRTopic Disposition NMP2 ResultInitiating Event Categories and Frequency
[IComponent Reliability Operator ResponseSuccess CriteriaExternal EventsShutdown RiskPRA Quality ]]In accordance with M+LTR SER Limitation and Condition 12.21, a plant-specific probabilistic risk assessment (PRA) evaluation was performed, which included CDF and LERF effectsassociated with operation in the MELLLA+ operating domain. The evaluation scope included allof the elements of Section 10.5, Individual Plant Examination, of the M+LTR (Reference 1).The associated PRA report is provided as Attachment 4 to the NMPNS MELLLA+ LAR.The proposed MELLLA+ operating region for NMP2 has been reviewed to determine the effecton the PRA. The PRA is based on the EPU MELLLA operating region and includes internalevents as well as fire and seismic initiating events. The effect of MELLLA+ on the PRA is very10-6 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)low and meets NRC guidelines in RG 1.174 (Reference
: 43) for CDF and LERF. MELLLA+ hasno effect on the risk associated with accidents initiated during shutdown conditions.
The estimated risk increase for at-power events due to MELLLA+ is a delta CDF of 1E-8 anddelta LERF of 3E-9. This represents a very small risk change in RG 1.174 (Reference 43).Based on these results, the proposed MELLLA+ operating region is acceptable on a risk basis.Risk Metric NMP2 EPU MELLLA+ Risk IncreaseCDF 3.77E-6 3.78E-6 IE-8LERF 3.92E-7 3.95E-7 3E-9Sensitivity analyses results also demonstrate a low risk with CDF and LERF changes no morethan 1E-7.10.5.1 Initiating Event Categories and Frequency The MELLLA+ core operating range expansion involves changes to the operating power/core flow map and a small number of setpoints.
There is no change in the operating
: pressure, power,steam flow rate, and FW flow rate. MELLLA+ implementation does not include changes toplant hardware or operating procedures that would create additional event categories or have asignificant effect on initiating event frequencies.
]]As noted in Section 2.4, the BSP, which is considered a part of the DSS-CD stability
: solution, may be used when the OPRM system is temporarily inoperable.
[[1]10.5.2 Component and System Reliability
[[]] There is no change in the operating
: pressure, power, steam flowrate, and FW flow rate. The MELLLA+ core operating range expansion does not require majorplant hardware modifications.
[[]] TheTS ensure that plant and system performance parameters are maintained within the values10-7 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)assumed in the safety analyses.
The TS setpoints, AVs, operating limits, and the like are selectedsuch that the equipment parameter values are equal to or more conservative than the values usedin the safety analyses.
[[]]10.5.3 Operator ResponseThe operator responses to anticipated occurrences, accidents, and special events for EPU withMELLLA+ conditions are basically the same as for EPU conditions.
Minor changes to ATWSoperator response in the PRA has occurred due to small reductions in timing for operator actionsduring an ATWS event. [[1]Because decay heat is unchanged, the time for boil-off is unchanged.
Therefore, long-term corecooling is not affected by the MELLLA+ operating range expansion.
]] The minimum operatoraction time to initiate SLS is 2 minutes and the minimum operator action time to inhibit ADSand start water level reduction, if necessary, (i.e., motor-driven FW pump nuclear power plants)is 90 seconds in ATWS analyses (Section 9.3.1). SLS initiation is automatic at NMP2, thuscritical operator action to initiate SLS is not required in the NMP2 PRA. The minimum operatoraction time to inhibit ADS and start water level reduction is potentially
: reduced, but this wasfound to have an insignificant effect on risk.[[I10.5.4 Success CriteriaSystems success criteria credited in a PRA to perform the critical safety functions were analyzedbased on MELLLA+.
Reactor thermal power, operating
: pressure, steam flow, and FW flow arenot changed by MELLLA+.
The power conversion
: systems, electrical
: systems, and otherauxiliary systems are not changed as a result of MELLLA+ operation.
Also, MELLLA+ doesnot change the operating conditions of systems modeled in the PRA. There is no effect on thesuccess criteria provided for the critical safety functions in the PRA; reactivity
: control, pressurecontrol, inventory control at high pressure, emergency depressurization, inventory control at lowpressure and containment heat removal; the following summarizes:
10-8 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)1) Reactivity Control -The number of control rods and reactor protection system (RPS)success criteria is unchanged.
One of two SLS pumps as a successful alternate shutdownsystem is unchanged, and in fact, this success criterion is further supported by the MELLLA+evaluations and the increase in boron-10 enrichment.
Although MELLLA+ has no effect onthe probability of scram failure, the plant may be at a slightly higher power during ATWSuntil SLS is injected.
This can affect the timing of operator response as described inSection 3.2.5 of Attachment 4 to the NMPNS MELLLA+ LAR.2) Pressure Control (RPV Overpressure Protection)
-There is no effect on the number ofSRVs required for success.
RPV dome operating pressure is not increased and there is noeffect for non-ATWS events. The higher power condition during ATWS was evaluated andthe assumed success criteria (16 of 18 SRVs required) in the PRA is still met withMELLLA+ conditions.
GEH analysis indicates margin in over pressure protection with twoSRVs OOS; therefore, the probability of overpressure due to failure of several SRVs is stilldominated by common cause failure of the SRVs, which is unchanged in the PRA.3) Pressure Control (SRVs Reclose)
-The success criteria is that all SRVs reclose, which isunchanged.
There is no effect on the number of SRV challenges for non-ATWS events asoperating pressure and power is not changed.
: However, the SRVs are likely open for alonger time during ATWS due to higher initial power level. The NMP2 turbine bypass israted at approximately 18.5% of rated steam flow. Thus, until power level is reduced to theequivalent bypass flow rate, SRVs will be open. In the case of a more severe transient suchas closure of all MSIVs, SRVs will be open until SLS is injected;
: however, the increased boron-10 enrichment ensures that the time to reactor shutdown is not increased due toMELLLA+.
The potential increase in probability of a stuck open SRV in the ATWS modelis considered with regard to PRA model change (see Section 3.3 of Attachment 4 to theNMPNS MELLLA+ LAR).4) High Pressure Injection
-There is no change in the number of pumps required for success.The MELLLA+ plant changes do not result in changes to injection
: systems, and reactorpower and pressure are unchanged.
Thus, there is no effect on injection system successcriteria for non-ATWS events. The potential for higher power level during ATWS until SLSinjection does not affect the systems credited for initial level control.
The timing associated with operator response is evaluated (see Sections 3.2.5 and 3.3 of Attachment 4 to theNMPNS MELLLA+ LAR).5) Emergency Depressurization
-There is no change in the number of SRVs required tosupport low pressure injection success.
MELLLA+ does not involve changes to the ADS anddoes not change reactor power or pressure.
Although ATWS power is potentially higheruntil SLS is injected, there is no effect on success criteria.
The timing associated withoperator response is evaluated (see Sections 3.2.5 and 3.3 of Attachment 4 to the NMPNSMELLLA+ LAR).6) Low Pressure Injection
-There is no change in the systems and number of pumps requiredfor success.
The MELLLA+ plant changes do not result in changes to injection
: systems, andreactor power and pressure are unchanged.
Thus, there is no effect on injection system10-9 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)success criteria for non-ATWS events. The potential for slightly higher power level duringinitial stages of ATWS does not affect the systems credited for level control after emergency depressurization and during SLS injection.
: 7) Containment Heat Removal -There is no change to the systems and success criteria forthis function.
Plant changes for MELLLA+ do not result in changes to containment heatremoval systems, and reactor power and pressure are unchanged.
Thus, there is no effect onheat removal success criteria for non-ATWS events. Also, for mitigated ATWS events (SLSinjection),
the RHR success criteria are unchanged.
The potential reduction in time to alignRHR is considered in Section 3.2.5 of Attachment 4 to the NMPNS MELLLA+ LAR.Although the suppression pool heat-up could be initially faster during ATWS due topotentially higher power level, the SLS increased boron-10 enrichment maintains theintegrated containment heat up unchanged.
: 8) Containment Response
-Containment analysis for LOCA and ATWS under MELLLA+conditions indicate the dynamic loads and containment conditions remain acceptable.
Noeffect on the PRA was identified (see Section 3.2.7 "Level 2 Model" of Attachment 4 to theNMPNS MELLLA+ LAR).The operating range expansion involves changes to the operating power/core flow map and asmall number of setpoints.
There is no change in the operating
: pressure, power, steam flow rate,and FW flow rate. The MELLLA+ operating range expansion does not impose any additional requirements on any of the safety, BOP, electrical, or auxiliary systems.
Adequate SRV capacityis provided to ensure that the ATWS overpressure requirement for MELLLA+ is satisfied.
Therefore, MELLLA+ operating range expansion will not affect the PRA success criteria.
10.5.5 External EventsThe operating range expansion is not expected to affect the elements of an internal event PRA, asdiscussed in Sections 10.5.1 to 10.5.4. Therefore, there is no effect on the external events PRA.10.5.6 Shutdown RisksThe operating range expansion does not change the shutdown conditions; therefore, it has noeffect on the plant PRA shutdown risks.10.5.7 PRA QualityMELLLA+ does not have a significant effect on any PRA elements.
The NMP2 PRA underwent an Internal Events and Internal Flooding industry peer review in August 2009 utilizing ASME/ANS RA-Sa-2009 and RG 1.200 Revision 2 (Reference 44). Subsequent post-peer review updates to the PRA have resolved most observations as well as incorporated the effect ofEPU. The remaining open observations were reviewed with respect to this application and werefound to have a negligible risk effect.Besides including EPU, the NMP2 PRA scope also includes the results of the individual plantexamination of external events (IPEEE) for fires and seismic initiating events at power. Thequality of the External Events modeling has not been peer reviewed against RG 1.200 Revision 2(Reference
: 44) and ASME/ANS RA-Sa-2009;
: however, the quality was found acceptable for the10-10 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)NMP2 emergency diesel generator (EDG) allowable outage time (AOT) application approved bythe NRC in 2011 (Reference 45). Also, the risk effect associated with the MELLLA+ operating range on external events risk is minimal.10.6 OPERATOR TRAINING AND HUMAN FACTORSSome additional training is required to prepare for NMP2 operation in the MELLLA+ operating domain. The topics addressed in this evaluation are:Topic I M+LTR Disposition NMP2 ResultOperator Training and Human Factors 1 ]]The description of the Operator Training and Human Factors topic in the M+LTR describes thatthe operator training program and plant simulator will be evaluated to determine the specificchanges required.
The selection of training topics, operator
: training, the control roommodifications, and simulator modifications are within the scope of the Licensee.
Requiredchanges are part of the MELLLA+ implementation plan and will be made consistent with theLicensee's current plant training program requirements.
These changes will be made consistent with similar changes made for other plant modifications and include any changes to TS, EOPs,and plant systems.The operator responses to anticipated occurrences, accidents, and special events are notsignificantly affected by operation in the MELLLA+ domain. Significant events result inautomatic plant shutdown (scram).
Some events result in automatic RCPB pressure relief, ADSactuation and/or automatic ECCS actuation (for low water level events).
MELLLA+ operating domain expansion does not cause changes in any of the automatic safety functions.
After theautomatic responses have initiated, the operator actions for plant safety (e.g., maintaining safeshutdown, core cooling, and containment cooling) do not change for MELLLA+ operating domain expansion.
As part of the NMPNS MELLLA+ LAR, the SLS has been modified by increasing the isotopicenrichment of boron-10 in the sodium pentaborate solution as described in Section 6.5. Thisresults in an effect in the ATWS response and is evaluated in Section 9.3. 1.Consistent with the requirements for the plant-specific analysis as described in the M+LTR, theoperator training program and plant simulator will be evaluated to determine the specific changesrequired.
Simulator changes and fidelity validation will be performed in accordance withapplicable ANSI standards currently being used at the training simulator.
Section 10.9 addresses the MELLLA+ operating domain effects on the EOPs and the abnormal operating procedures (AOPs). Operators will be trained regarding changes to procedures, including the limitation tonot perform LPRM calibrations in the prohibited region to the left of the line illustrated onFigure 5-1.The primary effects of MELLLA+ operating domain expansion on MCR operation involvechanges to the power/flow map. Other than the changes to the computer display for thepower/flow map, there are no major physical changes to the MCR controls,
: displays, or alarms asa result of MELLLA+ operating domain expansion.
Some changes are required to MCR panel10-11 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)board alarm settings and automatic actuation setpoints to accommodate changes due toMELLLA+ operating domain expansion.
The SLS modification to increase the isotopicenrichment of boron-10 in the sodium pentaborate solution (as described in Section 6.5) resultsin a reduction in solution storage tank minimum required volume and associated alarm level.These changes do not affect human factors.The APRM STP scram and rod block AVs are also being changed as a result of MELLLA+operating domain expansion.
These changes are described in Section 5.3.The SLS is modified by: (1) increasing the boron-10 enrichment in the sodium pentaborate solution in the SLS; (2) decreasing the sodium pentaborate solution volume stored in the SLSstorage tank; (3) reducing the injection flow requirement for ATWS response from two SLSpumps to one pump required to meet 10 CFR 50.62 for ATWS mitigation, though both SLSpumps would actually operate during an event; and (4) modifying instrumentation setpoints.
The changes required to adopt the MELLLA+ power/flow map, DSS-CD (including automatic actuation setpoints),
and the modifications to SLS are implemented as design changes inaccordance with the NMP2 approved change control procedures.
The change control processincludes a review by operations and training personnel.
Training and implementation requirements are identified and tracked, including effects on the simulator.
Verification oftraining is required as part of the design change closure process.There are no planned upgrades of controls,
: displays, or alarms from analog to digital instruments as part of MELLLA+ operating domain expansion.
There are no changes to the analog anddigital inputs for the safety parameter display system (SPDS) for MELLLA+ operating domainexpansion.
Training required to operate NMP2 following the MELLLA+ operating domain expansion willbe conducted prior to operation in the MELLLA+ domain. Training for the MELLLA+ startuptesting program will be performed using "just in time" training of plant operation personnel where appropriate.
Data obtained during operation in the MELLLA+ domain will beincorporated into additional
: training, as needed. The classroom training will cover variousaspects of MELLLA+ operating domain expansion, including changes to the power/flow map,changes to important setpoints, changes to plant procedures, and startup test procedures.
Theclassroom training may be combined with simulator training for normal operational sequences unique to operation in the MELLLA+ domain. The plant dynamics do not change substantially for operation in the MELLLA+ domain. Enhanced training on ATWS event mitigation in theMELLLA+ domain, FW pump trip transient, and RPT transient will be conducted.
The evaluation of the NMP2 operator training and human factors is consistent with the guidancepresented in the M+LTR and meets current industry standards.
10.7 PLANT LIFEThe plant life evaluation identifies degradation mechanisms influenced by increases in fluenceand flow rate. The topics addressed in this evaluation are:10-12 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Topic M+LTR Disposition NMP2 ResultIrradiated Assisted Stress Corrosion Cracking (IASCC)Flow Accelerated Corrosion 10.7.1 Irradiated Assisted Stress Corrosion CrackingWith regard to IASCC, the M+LTR states that the longevity of most equipment is not affected bythe MELLLA+ operating domain expansion.
The peak fluence experienced by the reactorinternals may increase, representing a minor increase in the potential for IASCC. Therefore, thecurrent inspection strategy for the reactor internal components is adequate to manage anypotential effects of MELLLA+.Section 3.2.1 provides an evaluation of the change in fluence experienced by the reactorinternals.
The change in fluence is minor, resulting in an insignificant change in the potential forIASCC. Therefore, the current inspection strategy based on the BWRVIP (Reference
: 46) issufficient to address the small increase in fluence.Fluence calculations performed at MELLLA+ conditions as required by M+LTR SER Limitation and Condition 12.22 indicate that only the top guide and shroud exceed the 5E20 n/cm2 threshold value for IASCC. The core plate fluence was calculated to be 5.95E20 n/cm2, however, whilethis value is slightly above the IASCC threshold, it is actually a decrease from the permitted CLTP value, thus it has no effect. In-core instrumentation dry tubes and guide tubes are includedin the evaluation due to an existing identification as being susceptible to IASCC in BWRVIP-47 (Reference 47).The increase in fluence due to MELLLA+ does cause an increased potential for IASCC.However, the inspection strategies and inspections recommended by BWRVIP-25, 26, 47, and76 (References 48, 49, 47, and 46, respectively) are based on component configuration and fieldexperience and this inspection program is considered adequate to address the increase inpotential for IASCC in the top guide, shroud, and in core instrumentation dry tubes and guidetubes.The BWRVIP evaluated the failure modes and effects of reactor vessel internals and published the results in BWRVIP-06 (Reference 50). This evaluation for the shroud concluded that theinspections and evaluations performed in response to Generic Letter (GL) 94-03 (Reference 51)provided conservative assurance that the shroud is able to perform its safety function.
Theinspections of the shroud and top guide are conducted using the guidance of BWRVIP-26, 76,and 183 (References 49, 46, and 52, respectively).
These guidelines in the areas of detection, inspection, repair or mitigation ensure the long-term function of these components.
10.7.2 Flow Accelerated Corrosion
[[]] for MELLLA+,
there is no increase in the MS flow rate and temperature, and the FWflow rate and temperature.
As described in Section 3.3.3, the MCO may increase in the MSLs.If this occurs, it may slightly increase the FAC rates for a small period of time during the cyclewhen the plant is operating at or near the MELLLA+ minimum CF. [[10-13 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)1]The Maintenance Rule also provides oversight for the other mechanical and electrical components important to plant safety, to guard against age-related degradation.
Therefore, nofurther evaluation of this topic is required per the M+LTR.[I ]] for NMP2, there are no significant changes in MS or FW temperatures and MS or FW flow rates. As discussed in Section 3.3.3,there is an increase in MCO during the cycle for a short duration.
This increase in MCO has nosignificant effect on FAC parameters.
Therefore, there is no significant change in the potential for FAC in the MS system.The evaluation of and inspection for flow-induced erosion/corrosion in piping systems affectedby FAC is addressed by compliance with NRC GL 89-08. The requirements of GL 89-08 areimplemented at NMP2 by utilization of the Electric Power Research Institute generic program,"CHECWORKSTM.''
NMP2-specific parameters are entered into this program to developrequirements for monitoring and maintenance of specific system piping. No changes arerequired to the NMP2-specific parameters that are entered into the CHECWORKSTM program.The FAC monitoring programs are adequate to manage potential effects of MELLLA+ operating domain expansion.
In addition to FAC, a periodic non-destructive examination program was established to inspectsafety-related piping and heat exchangers at known or suspected high corrosion, biofouling orsilt buildup areas in response to GL 89-13. This program is supplemented by visual inspections of opened piping and heat exchangers whenever possible.
The Maintenance Rule also provides oversight for other mechanical and electrical components important to plant safety, to monitor performance and guard against age-related degradation.
The longevity of NMP2 equipment is not affected by the MELLLA+ operating domainexpansion.
[[ ]], and Section 3.3.4.e, the MCO for NMP2 mayincrease to a maximum value of 0.25 wt.% for a period of time during the cycle when NMP2 isoperating at or near the MELLLA+ minimum CF rate. The EPU FAC evaluation for steampiping assumed a 0.25 wt.% MCO, which bounds the maximum predicted 0.236 wt.% MCO inthe MELLLA+ operating domain. NMP2 implements programs adequate to manage this changein the erosion/corrosion rate. [[10-14 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)10.8 NRC AND INDUSTRY COMMUNICATIONS The topic addressed in this evaluation is:Topic M+LTR Disposition NMP2 ResultPlant Disposition of NRC and Industry Communications
]] NRC and industry communications could affect the plant design and safetyanalyses.
As discussed in Section 1.0, the MELLLA+ operating domain expansion has a limitedeffect on the safety evaluations and system assessments.
Because the maximum thermal powerand CF rate do not change for MELLLA+ operating domain expansion, the effect of the changesis limited to the NSSS, primarily within the core. The evaluations and calculations included inthis M+SAR, along with any supplements, demonstrate that the MELLLA+ operating domainexpansion can be accomplished within the applicable design criteria.
Because these evaluations of plant design and safety analyses inherently include any effect as a result of NRC and industrycommunications, it is not necessary to review prior communications and no additional information is required in this area.1]10.9 EMERGENCY AND ABNORMAL OPERATING PROCEDURES EOPs and AOPs can be affected by MELLLA+ operating domain expansion.
The topicsaddressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultEmergency Operating Procedures
[[Abnormal Operating Procedures 10.9.1 Emergency Operating Procedures EOPs include variables and limit curves which define conditions where operator actions areindicated.
The EOPs remain symptom-based and thus the operator actions remain unchanged.
MELLLA+ operating domain expansion is not expected to affect the NMP2 EOPs. However, inaccordance with M+LTR SER Limitation and Condition 12.23.4, the EOPs will be reviewed forany effect and revised as necessary prior to implementation of MELLLA+ operating domainexpansion.
Any changes identified to the EOPs will be included in the operator training to beconducted prior to implementation of MELLLA+.
The ATWS calculation performed forMELLLA+ was based on the NMP2 operator actions from the EOPs.10.9.2 Abnormal Operating Procedures NMP2 refers to AOPs as special operating procedures (SOPs). SOPs include event basedoperator actions.
No significant SOP revisions are expected as a result of MELLLA+ operating domain expansion.
: However, the SOPs will be reviewed for any effect and revised as necessary prior to implementation of MELLLA+ operating domain expansion.
Any changes identified to10-15 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)the SOPs will be included in the operator training to be conducted prior to implementation ofMELLLA+.10-16 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)11.0 LICENSING EVALUATIONS The licensing evaluations addressed in this section include:* Effect on TS" Environmental Assessment
* Significant Hazards Consideration Assessment 11.1 EFFECT ON TECHNICAL SPECIFICATIONS The NMP2 TS that are affected by a MELLLA+ operating domain expansion are provided in theNMPNS MELLLA+ LAR. The implementation of MELLLA+ requires revision of a limitednumber of the NMP2 TS, including a prohibition on the intentional operation with only a singlerecirculation loop in operation while in the MELLLA+ operating domain, as defined in theCOLR. In addition, changes to the NMP2 TS are required to incorporate the DSS-CD stability solution option and changes to the SLS (including increasing the boron-10 isotopic enrichment inthe sodium pentaborate
: solution, decreasing the minimum net volume stored in the SLS tank, andincreasing the SLS pump discharge pressure requirements).
11.2 ENVIRONMENTAL ASSESSMENT The environmental effects of MELLLA+ operating domain expansion are controlled at the samelimits as the current analyses.
None of the present limits for plant environmental releases areincreased as a consequence of MELLLA+ operating domain expansion.
MELLLA+ has noeffect on the non-radiological elements of concern, and the plant will be operated in anenvironmentally acceptable manner as documented by the Environmental Assessment forNMP2's current licensed operating domain. Existing
: federal, state, and local regulatory permitspresently in effect accommodate the MELLLA+ operating domain expansion withoutmodification.
The evaluation of the effects of MELLLA+ operating domain expansion on normal radiological effluents is included in Section 8.0. There will be no change in the radiological effluents released to the environment due to the MELLLA+ operating domain expansion.
The normaleffluents and doses remain well within the 10 CFR 20 limits and the 10 CFR 50 Appendix Iguidance.
There is no change to the predicted doses from postulated accidents and the10 CFR 50.67 dose criteria continue to be met. In addition, the quantity of spent fuel does notincrease as a result of MELLLA+ operating domain expansion.
The environmental evaluations also demonstrate that the MELLLA+ changes qualify for acategorical exclusion not requiring an environmental assessment in accordance with10 CFR 51.22(c)(9).
See the NMPNS MELLLA+ LAR for an evaluation of the10 CFR 51.22(c)(9) criteria.
11-1 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)11.3 SIGNIFICANT HAZARDS CONSIDERATION ASSESSMENT Increasing the operating domain can be done safely within plant-specific limits, and is a highlycost effective way to provide needed flexibility in the generating capacity.
The M+SARprovides the safety analyses and evaluations to justify expanding the CF rate operating domain.DSS-CD introduces an enhanced detection algorithm, the CDA, which reliably detects theinception of power oscillations and generates an early power suppression trip signal prior to anysignificant oscillation amplitude growth and MCPR degradation.
The SLS is used to mitigate the consequences of an ATWS event and is used to limit theradiological dose during a LOCA. The proposed changes do not affect the capability of the SLSto perform these two functions in accordance with the assumptions of the associated analyses.
The ATWS evaluation with the proposed changes incorporated demonstrated that all the ATWSacceptance criteria are met. The ability of the SLS to mitigate radiological dose in the event of aLOCA is not affected by these changes.
The increase in the boron-10 enrichment in the sodiumpentaborate solution for the SLS is sufficient to reduce the injection flow requirement from twoSLS pumps to one. This result represents an increase in SLS redundancy.
In the event of asingle SLS pump failure during a postulated ATWS, a single SLS pump will be capable ofproviding the design sodium pentaborate solution flow, thereby increasing safety margin.NMPNS currently requires two SLS pumps and is not proposing any changes to LimitingCondition for Operation (LCO) 3.1.7 or to the completion time of Required Action A.1 ofTS 3.1.7 to reflect this additional marginA complete Significant Hazards Consideration Assessment is provided in the NMPNSMELLLA+ LAR.11.3.1 Modification SummaryThe MELLLA+ core operating domain expansion does not require major plant hardwaremodifications.
The core operating domain expansion involves changes to the operating power/core flow map, minor system modifications, procedure
: changes, and changes to a smallnumber of instrument setpoints.
Because there is no change in the operating
: pressure, power,steam flow rate, and FW flow rate, there are no major modifications to other plant equipment.
The stability solution is being changed from Option III to the DSS-CD solution.
The DSS-CDsolution algorithm, licensing basis, and application procedures are generically described inNEDC-33075P (Reference 2), and are applicable to NMP2. The DSS-CD solution uses the samehardware as the current Option III solution.
To support this change, a new computer (i.e., theNUMAC interfacing computer) will be installed to convert the proprietary encrypted signal fromthe PRNM system, and supply the converted signal to NMP2's current processing computer.
The boron-10 enrichment in the sodium pentaborate solution in the SLS is increased from> 25 atom percent to > 92 atom percent.
The increase in the boron-10 enrichment in the sodiumpentaborate solution for the SLS is sufficient to: (1) decrease the sodium pentaborate solutionvolume stored in the SLS storage tank; and (2) maintain the ATWS margin equivalent to theOLTP/75%
flow basis and address the GEH SC 10-13 dilution flow safety communication (Reference 53). The higher enrichment also increases margin by meeting 10 CFR 50.62 for11-2 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)ATWS mitigation based on a single SLS pump, although TS requirements and LCO are notrelaxed.
In addition, SLS tank level instrument setpoints will be changed to account for thereduced SLS tank minimum volume related to the change to > 92 atom percent boron-10enrichment.
11.3.2 Discussion of MELLLA+ IssuesPlant performance and responses to hypothetical accidents and transients have been evaluated forthe MELLLA+ operating domain expansion license amendment.
This section summarizes theplant reactions to events evaluated for licensing the plant, and the potential effects on variousmargins of safety, and thereby concludes that no significant hazards consideration will beinvolved.
11.3.2.1 MELLLA+ Analysis BasisThe MELLLA+ safety analyses are based on a RG 1.49 (Reference
: 54) power factor times therated power level, except for some analyses that are performed at nominal rated power, eitherbecause the RG 1.49 power factor is already accounted for in the analysis methods or RG 1.49does not apply.11.3.2.2 Fuel Thermal LimitsNo change is required in the mechanical fuel design to meet the plant licensing limits whileoperating in the MELLLA+ domain. No increase in allowable peak bundle power is needed andfuel thermal design limits will be met in the MELLLA+ domain. The analyses for each fuelreload are required to meet the criteria accepted by the NRC as specified in Reference 4 orotherwise approved in an associated TS amendment request.
In addition, future fuel designs willmeet acceptance criteria approved by the NRC.11.3.2.3 Makeup Water SourcesThe BWR design concept includes a variety of ways to pump water into the reactor vessel to dealwith all types of events. There are numerous safety-related and non-safety related cooling watersources.
The safety-related cooling water sources alone can maintain core integrity for allpostulated events by providing adequate cooling water. There are high and low pressure, highand low volume, safety and non-safety grade means of delivering water to the vessel. Thesemeans include at least:" FW and Condensate Pumps" LPCS System" HPCS System" LPCI of the RHR System" RCIC System* SLS" CRD Pumps11-3 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Many of these diverse water supply means are redundant in both equipment and systems.The MELLLA+ operating domain expansion does not result in an increase or decrease in theavailable water sources, nor does it change the selection of those assumed to function in thesafety analyses.
NRC-approved methods were used to evaluate the performance of the ECCSduring postulated LOCAs.11.3.2.4 Design Basis Accidents DBAs are very low probability hypothetical events whose characteristics and consequences areused in the design of the plant, so that the plant can mitigate their consequences to withinacceptable regulatory limits. For BWR licensing evaluations, capability is demonstrated forcoping with: (1) the range of hypothetical pipe break sizes in the largest recirculation, steam, andFW lines; (2) a postulated break in one of the ECCS lines; and (3) the most limiting small lines.This break range bounds the full spectrum of large and small, high and low energy line breaksand demonstrates the ability of plant systems to mitigate the accidents while accommodating asingle active equipment failure in addition to the postulated LOCA. Several of the significant licensing assessments are based on the LOCA and include:* Challenges to Fuel (ECCS Performance Analyses) in accordance with the rules andcriteria of 10 CFR 50.46 and Appendix K where the limiting criterion is the fuel PCT.* Challenges to the Containment wherein the primary criteria of merit are the maximumcontainment pressure calculated during the course of the LOCA and maximumsuppression (cooling) pool temperature for long-term cooling.* DBA Radiological Consequences calculated and compared to the criteria of10 CFR 50.67.11.3.2.5 Challenges to FuelThe evaluation of the ECCS performance is provided in Section 4.3. With MAPLHGR setdownsas indicated for low flow conditions, the PCT calculated for a LOCA from the MELLLA+domain is bounded by the licensing basis PCT that was calculated based on rated flow.However, the ECCS performance evaluation (Section 4.3) demonstrates significant margin tocriteria of 10 CFR 50.46 at the reduced flow of MELLLA+ domain. Therefore, the ECCS safetymargin is not significantly affected by MELLLA+ operating domain expansion.
11.3.2.6 Challenges to the Containment The peak values for containment pressure and temperature for events initiated in the MELLLA+domain meet design requirements and confirm the suitability of the plant for operation in theMELLLA+ domain. The containment dynamic and structural loads for events initiated in theMELLLA+ domain continue to meet design requirements.
The containment pressure andtemperature remains below the design limits following any DBA. Therefore, the containment and its cooling systems are satisfactory for operation in the MELLLA+ domain.11-4 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)11.3.2.7 Design Basis Accident Radiological Consequences The magnitude of the potential radiological consequences depends on the quantity of fissionproducts released to the environment, the atmospheric dispersion
: factors, and the dose exposurepathways.
The atmospheric dispersion factors and the dose exposure pathways do not change.The quantity of activity released to the environment is a function of the activity released from thecore and the transport mechanisms between the core and the effluent release point. Theradiological releases for events initiated in the MELLLA+ domain do not increase.
The radiological consequences of LOCA inside containment, MSLBA, ILBA, CRDA, and FHAare bounded by the evaluation at the current licensed operating domain and need not bereevaluated for the MELLLA+ domain. The radiological results for all accidents remain belowthe applicable regulatory limits for the plant.11.3.2.8 Anticipated Operational Occurrence AnalysesAOOs are evaluated to demonstrate consequences that meet the SLMCPR. The SLMCPR isdetermined using NRC-approved methods.
The limiting transients are core specific and areanalyzed for each reload fuel cycle to meet the licensing acceptance criteria (Section 2.2.1).Therefore, the margin of safety to the SLMCPR is not affected by operation in the MELLLA+domain.11.3.2.9 Combined EffectsDBAs are postulated using deterministic regulatory criteria to evaluate challenges to the fuel,containment, and off-site radiation dose limits. The off-site dose evaluation performed inaccordance with RG 1.3 (Reference
: 55) and Standard Review Plan (SRP) 15.6.5 calculates moresevere radiological consequences than the combined effects of bounding DBAs that produce thegreatest challenge to the fuel and containment.
In contrast, the DBA that produces the highestPCT does not result in damage to the fuel equivalent to the assumptions used in the off-site doseevaluation, and the DBA that produces the maximum containment
: pressure, does not result inleak rates to the atmosphere equivalent to the assumptions used in the off-site dose evaluation.
Thus, the off-site doses calculated in conformance with RG 1.3 (Reference
: 55) and SRP 15.6.5are conservative compared to the combined effect of the bounding DBA evaluations.
11.3.2.10 Non-LOCA Radiological Release Accidents The limiting non-LOCA events were reviewed for the effect of MELLLA+.
The doseconsequences for the non-LOCA radiological release accident events are shown in Section 9.0 toremain below regulatory limits.11.3.2.11 Equipment Qualification Plant equipment and instrumentation have been evaluated against the applicable criteria.
Thequalification envelope either does not change due to the MELLLA+ operating domain expansion or is bounded by the current licensed operating domain.11-5 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)11.3.2.12 Balance-of-Plant Because the power, pressure, steam and FW flow rate, and FW temperature do not change forMELLLA+ operating domain expansion, there are no significant changes to the BOPsystems/equipment.
MELLLA+ may increase the moisture content in BOP MS piping andcomponents.
The increased moisture content affects FAC, which is discussed in Section 10.7.2.11.3.2.13 Environmental Consequences For operation in the MELLLA+ domain, the environmental effects will be controlled to the samelimits as for the current operating power/flow map. None of the present environmental releaselimits are increased as a result of MELLLA+ operating domain expansion.
As a result, it is concluded that the NMP2 MELLLA+ operating domain expansion does notconstitute an unreviewed environmental question and is eligible for categorical exclusion asprovided by 10 CFR 51.22(c)(9).
11.3.2.14 Technical Specifications ChangesThe TS ensure that plant and system performance parameters are maintained within the valuesassumed in the safety analyses.
The TS setpoints, AVs, operating limits, and the like are selectedsuch that the equipment parameter values are equal to or more conservative than the values usedin the safety analyses.
NMP2 TS changes are provided in the NMPNS MELLLA+ LAR.Instrument uncertainties were properly considered for the setpoint changes associated withMELLLA+ operating domain expansion.
The TS also address equipment operability (availability) and put limits on EOOS (not available for use) times such that the plant can be expected to have the complement of equipment available to mitigate abnormal plant events assumed in the safety analyses.
Because the safety analysesfor the MELLLA+ operating domain expansion show that the results are within regulatory limits,there is no undue risk to public health and safety.The implementation of MELLLA+ requires revision of a limited number of the NMP2 TS,including a prohibition on the intentional operation with only a single recirculation loop inoperation while in the MELLLA+ operating domain as defined in the COLR. In addition, changes to the NMP2 TS are required to incorporate the DSS-CD stability solution option andchanges to the SLS (including increasing the boron-10 isotopic enrichment in the sodiumpentaborate
: solution, decreasing the minimum net volume stored in the SLS tank, and increasing the SLS pump discharge pressure requirements).
TS changes will provide a level of protection comparable to previously issued TS.11.3.2.15 Assessment of 10 CFR 50.92 CriteriaThe assessment of significant hazards consideration is included in the NMPNS MELLLA+ LAR.11.3.3 Discussion of DSS-CD Stability Solution IssuesFor the NMP2 MELLLA+ operating domain expansion, the long-term stability solution is beingchanged from the currently approved Option III solution to DSS-CD. The DSS-CD solutionalgorithm, licensing basis, and application procedures are generically described in11-6 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)NEDC-33075P (Reference
: 2) and NEDE-33147P-A (Reference 12), and are applicable to NMP2including any limitations and conditions associated with their use and approval.
The DSS-CD solution is designed to identify the power oscillation upon inception and initiatecontrol rod insertion to terminate the oscillations prior to any significant amplitude growth.DSS-CD provides protection against violation of the SLMCPR for anticipated oscillations.
DSS-CD is based on the same hardware design as Option III. However, it introduces anenhanced detection algorithm that detects the inception of power oscillations and generates anearlier power suppression trip signal exclusively based on successive period confirmation recognition.
The existing Option III algorithms are retained (with generic setpoints) to providedefense-in-depth protection for unanticipated reactor instability events.11.3.4 Discussion of SLS ChangesThe SLS is described in Section 9.3.5 of the NMP2 USAR. The system provides a backupcapability for shutting down the reactor.
The SLS is needed only in the event that sufficient control rods cannot be inserted into the reactor core to accomplish shutdown and cooldown in thenormal manner. To accomplish this function, the SLS injects a sodium pentaborate solution intothe reactor.The specified neutron absorber solution is sodium pentaborate.
It is prepared by dissolving granularly-enriched sodium pentaborate in demineralized water (NMP2 USAR Section 9.3.5.2).
The boron absorbs thermal neutrons and thereby terminates the nuclear fission chain reaction inthe uranium fuel. The sodium pentaborate also acts as a buffer to maintain the pool pH at orabove 7.0 to prevent the re-evolution of iodine, when mixed in the suppression pool following aLOCA accompanied by significant fuel damage (NMP2 USAR Section 9.3.5.1).
The NMPNS MELLLA+ LAR contains an evaluation utilizing a method provided inNRC-approved LTR NEDE-31096P-A (Reference
: 56) that demonstrates the boron equivalency requirement of 10 CFR 50.62(c)(4) is met, when the changes to the SLS flow rate and theboron-10 isotope enrichment are included.
In the event of a single SLS pump failure during apostulated ATWS, a single SLS pump will be capable of injecting sufficient negative reactivity, thereby increasing safety margin.The proposed boron-10 enrichment changes do not affect the capability to achieve and maintaina pH above 7.0 in the suppression pool following a LOCA, because the chemical properties andconcentration of the sodium pentaborate solution injected into the suppression pool will remainthe same. Given the reduced volume of solution that will be available, there will be a two hourreduction in the time available to add boron to the suppression pool to maintain the pH above 7.0(the nominal time based on a low level alarm is within 22 hours versus the current requirement of within 24 hours). The 22 hours remains within the guideline of less than 24 hours with a largemargin to the minimum requirements for a manual operator action of 30 minutes.11-7 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)
==12.0 REFERENCES==
: 1. GE Hitachi Nuclear Energy, "General Electric Boiling Water Reactor MaximumExtended Load Line Limit Analysis Plus," NEDC-33006P-A, Revision 3, June 2009.2. GE Hitachi Nuclear Energy, "GE Hitachi Boiling Water Reactor Detect and SuppressSolution
-Confirmation Density,"
NEDC-33075P, Revision 7, June 2011; and AnthonyJ. Mendiola (NRC) to Jerald G. Head (GEH), "Revised Draft Safety Evaluation for GE-Hitachi Nuclear Energy Americas, LLC Topical Report NEDC-33075P, Revision 7, 'GEHitachi Boiling Water Reactor Detect and Suppress Solution
-Confirmation Density'(TAC No. ME6577),"
MFN-13-045, August 6, 2013.3. a. GE Hitachi Nuclear Energy, "Applicability of GE Methods to Expanded Operating Domains,"
NEDC-33173P-A, Revision 4, November 2012.b. Letter, Richard E. Kingston (GEH) to NRC, "Clarification of Stability Evaluations-NEDC-33173P,"
MFN 08-541, June 25, 2008.c. Letter, James F. Harrison (GEH) to NRC, "Implementation of MethodsLimitations-NEDC-33173P,"
MFN 08-693, September 18, 2008.d. Letter, James F. Harrison (GEH) to NRC, "NEDC-33173P
-Implementation ofLimitation 12," MFN 09-143, February 27, 2009.e. GE Hitachi Nuclear Energy, "Implementation of PRIME Models and Data inDownstream Methods,"
NEDO-33173 Supplement 4-A, Revision 1, November 2012.4. GE Hitachi Nuclear Energy, "General Electric Standard Application for Reactor Fuel,"NEDE-2401 1-P-A- 19 and NEDE-2401 1-P-A- 19-US, May 2012.5. GE Nuclear Energy, "Generic Guidelines for General Electric Boiling Water ReactorExtended Power Uprate,"
NEDC-32424P-A, February 1999.6. GE Nuclear Energy, "Generic Evaluations of General Electric Boiling Water ReactorExtended Power Uprate,"
NEDC-32523P-A, February 2000, Supplement 1, Volume I,February 1999, and Supplement 1, Volume II, April, 1999.7. GE Nuclear Energy, "Constant Pressure Power Uprate,"
NEDC-33004P-A, Revision 4,July 2003.8. GE Nuclear Energy, "The GE Pressure Suppression Containment System Analytical Model," NEDM- 10320, March 1971.9. NUREG-0808, U.S. Nuclear Regulatory Commission, "Mark II Containment ProgramLoad Evaluation and Acceptance Criteria,"
August 1981.10. GE Nuclear Energy, "General Electric Model for LOCA Analysis in Accordance with10 CFR 50 Appendix K," NEDE-20566-P-A, Revision 2, September 1986.12-1 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)11. GE Nuclear Energy, "Qualification of the One-Dimensional Core Transient Model(ODYN) for Boiling Water Reactors (Supplement 1 -Volume 4)," NEDC-24154P-A, Revision 1, Supplement 1, February 2000.12. GE Hitachi Nuclear Energy, "DSS-CD TRACG Application,"
NEDE-33147P-A, Revision 4, August 2013.13. Letter, Thomas Lynch (NMPNS) to Document Control Desk (NRC), "Nine Mile PointNuclear Station Unit No. 2: Docket No. 50-410, Supplemental Information Regarding Nine Mile Point Nuclear Station, Unit No. 2 -Re: The License Amendment Request forExtended Power Uprate Operation (TAC No. ME1476) -Update to License Amendment Request,"
October 8, 2010.14. Letter, NRC to Ken Langdon (NMPNS),
"Nine Mile Point Nuclear Station, Unit No. 2 -Issuance of Amendment Re: Extended Power Uprate (TAC No. ME1476),"
December 22, 2011.15. Global Nuclear Fuel, "The PRIME Model for Analysis of Fuel Rod Thermal-Mechanical Performance,"
NEDC-33256P-A, NEDC-33257P-A and NEDC-33258P-A, Revision 1,September 2010.16. GE Nuclear Energy, "General Electric Methodology for Reactor Pressure Vessel FastNeutron Flux Evaluations,"
NEDC-32983P-A, Revision 2, January 2006.17. Regulatory Guide 1.190, "Calculational and Dosimetry Methods for Determining Pressure Vessel Neutron Fluence,"
U.S. NRC, March 2001.18. NRC Generic Letter 88-01, "NRC Position on IGSCC in BWR Austenitic Stainless SteelPiping,"
January 25, 1988.19. "Revised Risk-Informed In-Service Inspection Evaluation Procedure,"
EPRI TR-1 12657,Revision B, W03230, Final Report, July 1999.20. Nuclear Regulatory Commission, "Technical Report on Material Selection andProcessing Guidelines for BWR Coolant Pressure Boundary Piping,"
NUREG-0313, Revision 2, January 1988.21. BWRVIP-75, "BWR Vessel and Internals Project Technical Basis for Revisions toGeneric Letter 88-01 Inspection Schedules,"
October 1999.22. American National Standards Institute, ANSI B31.1-1977, including 1978 WinterAddenda, "Power Piping."23. GE Hitachi Nuclear Energy, "Safety Analysis Report for Nine Mile Point Nuclear StationUnit 2 Constant Pressure Power Uprate,"
NEDC-33351 P, Revision 0, May 2009.24. GE Nuclear Energy, "Mark II Containment Dynamic Forcing Functions Information Report,"
NEDO-21061, Revision 4, November 1981.12-2 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)25. NUREG-0487, U.S. Nuclear Regulatory Commission, "Mark II Containment Lead PlantProgram Load Evaluation and Acceptance Criteria,"
October 1978, Supplement 1,September 1980, and Supplement 2, February 1981.26. Section 6A.4 of the NMP2 USAR.27. NRC Generic Letter 89-10, "Safety-Related Motor-Operated Valve Testing andSurveillance,"
June 28, 1989.28. NRC Generic Letter 89-16, "Installation of a Hardened Wetwell Vent," September 1,1989.29. NRC Generic Letter 95-07, "Pressure Locking and Thermal Binding of Safety-Related Power-Operated Gate Valves,"
August 17, 1995.30. NRC Generic Letter 96-06, "Assurance of Equipment Operability and Containment Integrity During Design-Basis Accident Conditions,"
September 30, 1996.31. Letter, Sam Belcher (NMPNS) to Document Control Desk (NRC), "Nine Mile PointNuclear Station Unit No. 2; Docket No. 50-410, Response to Request for Additional Information Regarding Nine Mile Point Nuclear Station, Unit No. 2- Re: The LicenseAmendment Request for Extended Power Uprate Operation (TAC No. ME1476) -Containment Accident
: Pressure, Combustible Gas Control, Pipe Stress Analysis, andBoral Monitoring Program,"
May 9, 2011.32. Regulatory Guide 1.1, "Net Positive Suction Head for Emergency Core Cooling andContainment Heat Removal System Pumps," U.S. NRC, November 2, 1970.33. GE Nuclear Energy, "Compilation of Improvements to GENE's SAFER ECCS-LOCA Evaluation Model," NEDC-32950P, Revision 1, July 2007.34. GE Nuclear Energy, "GESTR-LOCA and SAFER Models for Evaluation ofLoss-of-Coolant Accident Volume III, Supplement 1, Additional Information for UpperBound PCT Calculation,"
NEDE-23785P-A, Volume III, Supplement 1, Revision 1,March 2002.35. GE Nuclear Energy, "General Electric Instrument Setpoint Methodology,"
NEDC-31336P-A, September 1996.36. NRC Regulatory Issue Summary 2006-17, "NRC Staff Position on the Requirements of10 CFR 50.36, 'Technical Specifications,'
Regarding Limiting Safety System SettingsDuring Periodic Testing and Calibration of Instrument Channels,"
August 24, 2006.37. Letter, Technical Specifications Task Force (TSTF) to NRC, "Transmittal of RevisedTSTF-493 Revision 4," TSTF-09-29, dated January 5, 2010; and Letter, TSTF to NRC,"Transmittal of TSTF-493 Revision 4, Errata,"
TSTF- 10-07, dated April 23, 2010.38. GE Nuclear Energy, "Assessment of BWR Mitigation of ATWS, Volume II(NUREG-0460 Alternate No. 3)," NEDE-24222, December 1979.12-3 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)39. GE Nuclear Energy, "ATWS Rule Issues Relative to BWR Core Thermal-Hydraulic Stability,"
NEDO-32047-A, June 1995, (SER includes approval for: "Mitigation of BWRCore Thermal-Hydraulic Instabilities in ATWS," NEDO-32164, December 1992.).40. GE Nuclear Energy, "Mitigation of BWR Core Thermal-Hydraulic Instabilities inATWS," NEDO-32164, December 1992.41. GE Hitachi Nuclear Energy, "Migration to TRACG04 / PANAC 11 from TRACG02 /PANACIO for TRACG AOO and ATWS Overpressure Transients,"
NEDE-32906P, Supplement 3-A, Revision 1, April 2010.42. Letter from James F. Harrison (GEH) to NRC, "Use of the Shumway Tmin Correlation with Zircaloy for TRACG Analyses,"
MFN 13-073, September 9, 2013.43. Regulatory Guide 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis," U.S. NRC,Revision 2, May 2011.44. Regulatory Guide 1.200, "An Approach for Determining the Technical Adequacy ofProbabilistic Risk Assessment Results for Risk-Informed Activities,"
U.S. NRC,Revision 2, March 2009.45. Letter, Richard V. Guzman (NRC) to Kenneth Langdon (NMPNS),
"Nine Mile PointNuclear Station, Unit No. 2 -Issuance of Amendment Regarding Extension ofCompletion Time for an Inoperable Division 1 or Division 2 Diesel Generator (TACNo. ME3736),"
October 31, 2011.46. "BWR Core Shroud Inspection and Flaw Evaluation Guidelines,"
BWRVIP-76, EPRITR- 114232, November 1999.47. BWRVIP-47, "BWR Lower Plenum Inspection and Flaw Evaluation Guidelines,"
November 2004.48. BWRVIP-25, "BWR Core Plate Inspection and Flaw Evaluation Guidelines,"
December 1996.49. BWRVIP-26, "BWR Top Guide Inspection and Flaw Evaluation Guidelines,"
November 2004.50. BWRVIP-06-A, "Safety Assessment of BWR Reactor Internals,"
March 2002.51. NRC Generic Letter 94-03, "Intergranular Stress Corrosion Cracking of Core Shrouds inBoiling Water Reactors,"
July 25, 1994.52. BWRVIP-183, "Top Guide Grid Beam Inspection and Flaw Evaluation Guidelines,"
December 2007.53. GE Hitachi Nuclear Energy Safety Communication, "Standby Liquid Control SystemDilution Flow," SC 10-13, October 11, 2010.54. Regulatory Guide 1.49, "Power Levels of Nuclear Power Plants,"
U.S. NRC, Revision 1,December 1973 (Withdrawn July 2007).12-4 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)55. Regulatory Guide 1.3, "Assumptions Used for Evaluating the Potential Radiological Consequences of a Loss of Coolant Accident for Boiling Water Reactors,"
U.S. NRC,Revision 2, June 1974.56. GE Nuclear Energy, "Anticipated Transients Without Scram Response to NRC ATWSRule, 1OCFR50.62,"
NEDE-31096P-A, February 1987.57. Regulatory Guide 1.99, "Radiation Embrittlement of Reactor Vessel Materials,"
U.S.NRC, Revision 2, May 1988.58. GE Hitachi Nuclear Energy, "General Electric Boiling Water Reactor Detect andSuppress Solution-Confirmation Density,"
NEDC-33075P-A, Revision 6, January 2008.12-5 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Appendix ADisposition of additional limitations and conditions related to the final SE forNEDC-33173P, "Applicability of GE Methods to Expanded Operating Domains"There are 24 limitations and conditions listed in Section 9 of the Methods LTR SER. The tablebelow lists each of the 24 limitations and conditions.
The table also shows that NMP2 complieswith 14 of the limitations and conditions.
The table identifies which section of this M+SARdiscusses compliance with each limitation and condition.
Ten limitations and conditions are notapplicable to NMP2 for the following reasons.9.2 NMP2 MELLLA+ based on TGBLA06/PANACl1, not TGBLA04/PANAC 10.9.4 This penalty is specific for EPU applications.
Limitation and Condition 9.5 addresses MELLLA+ SLMCPR penalty.9.13 NMP2 MELLLA+ is less than 10 weight percent Gd.9.14 NMP2 MELLLA+ has a PRIME T-M and PRIME fuel temperature basis.9.15 NMP2 MELLLA+ licensing basis is not based on TRACG for the voidreactivity coefficient bias and uncertainties relative to lattice designs.9.16 NMP2 MELLLA+ licensing basis is not based on TRACG for the voidcoefficient biases and uncertainties for known dependencies.
9.18 Stability Setpoints Adjustment to DSS-CD because the significant conservatisms in the current licensing methodology and associated MCPRmargins are more than sufficient to compensate for the overall uncertainty in the OPRM instrumentation.
9.20 NMP2 MELLLA+ licensing basis is not based on TRACG for the Void-Quality Correlation.
9.21 NMP2 MELLLA+ is not based on a mixed core.9.22 NMP2 MELLLA+ is not based on unapproved fuel product lines.There is one remaining limitation and condition, Limitation and Condition 9.23 that relates toMELLLA+ eigenvalue tracking.
If NMP2 is the first implementation of MELLLA+,
then NMP2intends to comply with that limitation and condition.
The required data will be collected andevaluated in accordance with Limitation and Condition 9.23. This information will be submitted to the NRC in accordance with the limitation and condition following the implementation of theMELLLA+ expanded operating domain at NMP2.Note that Reference 3.c clarifies the implementation of Limitations and Conditions 9.3, 9.8, 9.17,and 9.19.A-I NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Appendix A (continued)
Disposition of additional limitations and conditions related to the final SE forNEDC-33173P, "Applicability of GE Methods to Expanded Operating Domains"Limitation Section of NMP2and M+SAR whichCondition Limitation andM+A whcNubrCondition Lmtion Te Limitation and Condition Description Disposition addresses theNumber Condition Title Lmtto nfrom NRC Limitation andSER Condition The neutronic methods used to simulate thereactor core response and that feed into theTGBLA/PANAC downstream safety analyses supporting Comply Table 1-1 and9.1 Version operation at EPU/MELLLA+
will apply Section 2.6.1TGBLA06/PANAC 11 or later NRC-approved version of neutronic method.For EPU/MELLLA+
applications, relying onTGBLA04/PANAC 10 methods, the bundleRMS difference uncertainty will be established from plant-specific core-tracking data, based Table 1-19.2 3D Monicore on TGBLA04/PANACI0.
The use of plant- N/Aspecific trendline based on the neutronic (1)method employed will capture the actualbundle power uncertainty of the coremonitoring system.A-2 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Limitation Section of NMP2and M+SAR whichCondition Limitation andM+A whhNubrCondition Lmtion Te Limitation and Condition Description Disposition addresses theNumber Condition Title Lmtto nfrom NRC Limitation andSER Condition Plant-specific EPU and expanded operating domain applications will confirm that the corethermal power to core flow ratio will not Sections 1.2.1 and 2.2.5exceed 50 MWt/Mlbrn/hr at any statepoint in93 Power/Flow the allowed operating domain. For plants that Comply (2)Ratio exceed the power-to-flow value of50 MWtiMlbm/hr, the application will provide Consistent withpower distribution assessment to establish that Reference 3.cneutronic methods axial and nodal powerdistribution uncertainties have not increased.
For EPU operation, a 0.02 value shall be added9.4 SLMCPR 1 to the cycle-specific SLMCPR value. Thisadder is applicable to SLO, which is derived N/A (3)from the dual loop SLMCPR value.This Limitation has been revised according toAppendix I of this SE.For operation at MELLLA+,
including operation at the EPU power levels at the9.5 SLMCPR 2 achievable CF statepoint, a 0.01 value shall be Comply Sections 2.2.1 and 2.2.5added to the cycle-specific SLMCPR value forpower-to-flow ratios up to 42 MWt/Mlbm/hr, and a 0.02 value shall be added to the cycle-specific SLMCPR value for power-to-flow ratios above 42 MWt/Mlbm/hr.
A-3 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Limitation Section of NMP2and M+SAR whichCondition Limitation andNubrCondition Lmtion Te Limitation and Condition Description Disposition addresses theNumber Condition Title Lmtto nfrom NRC Limitation andSER Condition The plant specific R-factor calculation at abundle level will be consistent with latticeaxial void conditions expected for the hot9.6 R-Factor channel operating state. The plant-specific Comply Section 2.2EPU/MELLLA+
application will confirm thatthe R-factor calculation is consistent with thehot channel axial void conditions.
For applications requesting implementation ofEPU or expanded operating domains,including MELLLA+,
the small and largebreak ECCS-LOCA analyses will include top-peaked and mid-peaked power shape in9.7 ECCS-LOCA 1 establishing the MAPLHGR and determining Comply Sections 4.3.2 and 4.3.3the PCT. This limitation is applicable to boththe licensing bases PCT and the upper boundPCT. The plant-specific applications willreport the limiting small and large breaklicensing basis and upper bound PCTs.A-4 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Limitation Section of NMP2and M+SAR whichCondition Limitation andMSA whcNubrCondition Lmtion Te Limitation and Condition Description Disposition addresses theNumber Condition Title Lmtto nfrom NRC Limitation andSER Condition The ECCS-LOCA will be performed for allstatepoints in the upper boundary of theexpanded operating domain, including theminimum CF statepoints, the transition Section 4.3.3statepoint, as defined in Reference 1 and the9.8 ECCS-LOCA 2 55 percent CF statepoint.
The plant-specific Comply (2)application will report the limitingECCS-LOCA results as well as the rated Consistent withpower and flow results.
The SRLR will Reference 3.cinclude both the limiting statepoint ECCS-LOCA results and the rated conditions ECCS-LOCA results.Plant-specific EPU and MELLLA+applications will demonstrate and documentthat during normal operation and core-wide AOOs, the T-M acceptance criteria asspecified in Amendment 22 to GESTAR II willbe met. Specifically, during an AOO, the9.9 Transient LHGR licensing application will demonstrate that the: Comply Section 9.1.11 (1) loss of fuel rod mechanical integrity willnot occur due to fuel melting and (2) loss offuel rod mechanical integrity will not occurdue to pellet-cladding mechanical interaction.
The plant-specific application will demonstrate that the T-M acceptance criteria are met for theboth the U02and the limiting GdO2rods.A-5 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Limitation and Section of NMP2Condition Limitation and M+SAR whichNumber Condition Title Limitation and Condition Description Disposition addresses thefrom NRC Limitation andSER Condition Each EPU and MELLLA+ fuel reload willdocument the calculation results of theTransient LHGR analyses demonstrating compliance to9.10 transient T-M acceptance criteria.
The plant Comply Section 9.1.1T-M response will be provided with the SRLRor COLR, or it will be reported directly to theNRC as an attachment to the SRLR or COLR.To account for the effect of the void historybias, plant-specific EPU and MELLLA+applications using either TRACG or ODYNwill demonstrate an equivalent to 10 percentmargin to the fuel centerline melt and the1 percent cladding circumferential plasticstrain acceptance criteria due to pellet-cladding mechanical interaction for all ofTransient LHGR limiting AOO transient events, including 9.11 3 EOOS. Limiting transients in this case, refers Comply Section 9.1.1to transients where the void reactivity coefficient plays a significant role (such aspressurization events).
If the void history biasis incorporated into the transient model withinthe code, then the additional 10 percent marginto the fuel centerline melt and the 1 percentcladding circumferential plastic strain is nolonger required.
A-6 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Limitation Section of NMIP2and M+SAR whichCondition Limitation andNumber Condition Title Limitation and Condition Description Disposition addresses thefombR C o o TLimitation andfrom NRC Condition SERIn MFN 06-481, GE committed to submitplenum fission gas and fuel exposure gammascans as part of the revision to the T-Mlicensing process.
The conclusions of theplenum fission gas and fuel exposure gammascans of GE 1Oxl 0 fuel designs as operatedwill be submitted for NRC staff review andLHGR and approval.
This revision will be accomplished Section 2.6.39.12 Exposure through Amendment to GESTAR II or in a ComplyQualification T-M licensing LTR. PRIME (a newly (4)developed T-M code) has been submitted tothe NRC staff for review (Reference 15).Once the PRIME LTR and its application areapproved, future license applications for EPUand MELLLA+ referencing LTRNEDC-33173P must utilize the PRIME T-Mmethods.Before applying 10 weight percent Gd tolicensing applications, including EPU andexpanded operating domain, the NRC staffApplication of needs to review and approve the T-M LTR Section 2.09.13 10 Weight demonstrating that the T-M acceptance criteria N/APercent Gd specified in GESTAR II and Amendment 22 to (5)GESTAR II can be met for steady-state andtransient conditions.
Specifically, the T-Mapplication must demonstrate that the T-Macceptance criteria can be met for thermalA-7 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Limitation Section of NMP2and M+SAR whichCondition Limitation andNumber Condition Title Limitation and Condition Description Disposition addresses thefombR C o o TLimitation andfrom NRC Condition SER IIoverpower (TOP) and mechanical overpower (MOP) conditions that bounds the response ofplants operating at EPU and expandedoperating domains at the most limitingstatepoints, considering the operating flexibilities (e.g., EOOS).Before the use of 10 weight percent Gd formodem fuel designs, NRC must review andapprove TGBLA06 qualification submittal.
Where a fuel design refers to a design withGd-bearing rods adjacent to vanished or waterrods, the submittal should include specificinformation regarding acceptance criteria forthe qualification and address any downstream effects in terms of the safety analysis.
The10 weight percent Gd qualifications submittal can supolement this report.Any conclusions drawn from the NRC staffPart 21 evaluation of the GE's Part 21 report will beEvaluation of applicable to the GESTR-M T-M assessment 9.14 GESTR-M Fuel of this SE for future license application.
GE N/A (6)submitted the T-M Part 21 evaluation, which isCalculation currently under NRC staff review. Uponcompletion of its review, NRC staff willinform GE of its conclusions.
A-8 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Limitation Section of NMP2and M+SAR whichCondition Limitation andM+A whhNubrCondition Lmtion Te Limitation and Condition Description Disposition addresses theNumber Condition Title Lmtto nfrom NRC Limitation andSER Condition The void reactivity coefficient bias and Section 2.29.15 Void Reactivity uncertainties in TRACG for EPU and N/A1 MELLLA+ must be representative of the (7)lattice designs of the fuel loaded in the core.A supplement to TRACG /PANAC 1I forAOO is under NRC staff review(Reference 41). TRACG internally models theresponse surface for the void coefficient biasesand uncertainties for known dependencies dueto the relative moderator density and exposureon nodal basis. Therefore, the void historybias determined through the methods reviewcan be incorporated into the response surface"known" bias or through changes in latticeVoid Reactivity physics/core simulator methods for9.16 2 establishing the instantaneous cross-sections.
N/A (7)Including the bias in the calculations negatesthe need for ensuring that plant-specific applications show sufficient margin. Forapplication of TRACG to EPU and MELLLA+applications, the TRACG methodology mustincorporate the void history bias. The mannerin which this void history bias is accounted forwill be established by the NRC staff SEapproving NEDE-32906P, Supplement 3,"Migration to TRACG04/PANAC 11 fromTRACG02/PANAC 10," May 2006A-9 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Limitation Section of NMP2and M+SAR whichCondition Limitation and Limitation and Condition Description Disposition addresses theNumber Condition Title Limitation andfrom NRC Condition SER Condition (Reference 41). This limitation applies untilthe new TRACG/PANAC methodology isapproved by the NRC staff.The instrumentation specification design baseslimit the presence of bypass voiding to5 percent (LRPM (sic) levels).
Limiting thebypass voiding to less than 5 percent forlong-term steady operation ensures that Section 2.1.2instrumentation is operated within theSteady-State 5 specification.
For EPU and MELLLA+9.17 Percent Bypass operation, the bypass voiding will be evaluated Comply (2)Voiding on a cycle-specific basis to confirm that thevoid fraction remains below 5 percent at all Consiste witLPRM levels when operating at steady-state conditions within the MELLLA+ upperboundary.
The highest calculated bypassvoiding at any LPRM level will be providedwith the plant-specific SRLR.A-10 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Limitation Section of NMP2and M+SAR whichCondition Limitation andNumber Condition Title Limitation and Condition Description Disposition addresses theLimitation andfrom NRC Condition SER Condition The NRC staff concludes that the presencebypass voiding at the low-flow conditions where instabilities are likely can result incalibration errors of less than 5 percent forStability OPRM cells and less than 2 percent for APRM98 Stabiity signals.
These calibration errors must be9.18 Setpoints accounted for while determining the setpoints N/A Section 2.4.1Adjustment for any detect and suppress long-term methodology.
The calibration values for thedifferent long-term solutions are specified inthe associated sections of this SE, discussing the stability methodology.
For applications involving PANCEA/ODYN/ISCOR/TASC for operation at EPU and MELLLA+,
an additional 0.01will be added to the OLMCPR, until such time Sections 2.2.2 and 9.1.1that GE expands the experimental databaseVoid-Quality supporting the Findlay-Dix void-quality (2),(10)9.19 Correlation 1 correlation to demonstrate the accuracy and Complyperformance of the void-quality correlation Consistent withbased on experimental data representative of Reference 3.cthe current fuel designs and operating conditions during steady-state, transient, andaccident conditions.
A-i I NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Limitation Section of NMP2and M+SAR whichCondition Limitation andM+ RwihNubrCondition Lmtion Te Limitation and Condition Description Disposition addresses theNumber Condition Title Lmtto nfrom NRC Limitation andSER Condition The NRC staff is currently reviewing Supplement 3 to NEDE-32906P, "Migration toTRACG04/PANAC1 1 fromTRACG02/PANAC 10," dated May 20060 Void-Quality (Reference 41). The adequacy of the TRACG9.20 Correlation 2 interfacial shear model qualification for N/A (7)application to EPU and MELLLA+ will beaddressed under this review. Any conclusions specified in the NRC staff SE approving Supplement 3 to LTR NEDC-32906P (Reference
: 41) will be applicable as approved.
Plants implementing EPU or MELLLA+ withmixed fuel vendor cores will provide plant-specific justification for extension of GE'sanalytical methods or codes. The content of Section 2.09.21 Mixed Core the plant-specific application will cover the N/AMethod 1 topics addressed in this SE as well as subjects (8)relevant to application of GE's methods tolegacy fuel. Alternatively, GE maysupplement or revise LTR NEDC-33173P (Reference
: 3) for mixed core application.
For any plant-specific applications ofTGBLA06 with fuel type characteristics not Section 2.09.22 Mixed Core covered in this review, GE needs to provide N/AMethod 2 assessment data similar to that provided for the (8)GE fuels. The Interim Methods review isapplicable to all GE lattices up to GEl4. FuelA-12 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Limitation Section of NMP2and M+SAR whichCondition Limitation andNumber Condition Title Limitation and Condition Description Disposition addresses thefombR C o o TLimitation andfrom NRC Condition SERlattice designs, other than GE lattices up toGE14, with the following characteristics arenot covered by this review:* square internal water channels watercrosses* Gd rods simultaneously adjacent to waterand vanished rods* 1 lxii lattices* MOX fuelThe acceptability of the modified epithermal slowing down models in TGBLA06 has notbeen demonstrated for application to these orother geometries for expanded operating domains.Significant changes in the Gd rod opticalthickness will require an evaluation of theTGBLA06 radial flux and Gd depletion modeling before being applied.
Increases inthe lattice Gd loading that result in nodalreactivity biases beyond those previously established will require review before the GEmethods may be applied.MELLLA+ In the first plant-specific implementation of9.23 Eigenvalue MELLLA+,
the cycle-specific eigenvalue Comply (9)Tracking tracking data will be evaluated and submitted A-13 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Limitation Section of NMP2and M+SAR whichCondition Limitation andNumber Condition Title Limitation and Condition Description Disposition addresses thefombR C o o TLimitation andfrom NRC Condition SERto NRC to establish the performance ofnuclear methods under the operation in thenew operating domain. The following datawill be analyzed:
* Hot critical eigenvalue,
* Cold critical eigenvalue,
* Nodal power distribution (measured andcalculated TIP comparison),
* Bundle power distribution (measured andcalculated TIP comparison),
* Thermal margin,* CF and pressure drop uncertainties, and* The MCPR importance parameter (MIP)Criterion (i.e., determine if core and fueldesign selected is expected to produce aplant response outside the priorexperience base).Provision of evaluation of the core-tracking data will provide the NRC staff with bases toestablish if operation at the expandedoperating domain indicates:
(1) changes in theperformance of nuclear methods outside theEPU experience base; (2) changes in theavailable thermal margins; (3) need forchanges in the uncertainties and NRC-A-14 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Limitation Section of NMP2and M+SAR whichCondition Limitation andNumber Condition Title Limitation and Condition Description Disposition addresses thefombR C o o TLimitation andfrom NRC Condition SERapproved criterion used in the SLMCPRmethodology; or (4) any anomaly that mayrequire corrective actions.The plant-specific applications will provideprediction of key parameters for cycleexposures for operation at EPU (andMELLLA+ for MELLLA+ applications).
Theplant-specific prediction of these keyparameters will be plotted against the EPUReference Plant experience base and4 Plant-Specific MELLLA+ operating experience, if available.
9.24 plant-pionc For evaluation of the margins available in the Comply Section 2.1.2Application fuel design limits, plant-specific applications will also provide quarter core map (assuming core symmetry) showing bundle power, bundleoperating LHGR, and MCPR for BOC, MOC,and EOC. Because the minimum margins tospecific limits may occur at exposures otherthan the traditional BOC, MOC, and EOC, thedata will be provided at these exposures.
A-15 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Appendix A (continued)
Disposition of additional limitations and conditions related to the final SE forNEDC-33173P, "Applicability of GE Methods to Expanded Operating Domains"Notes:1. As shown in Table 1-1, NMP2 used TGBLA06 and PANAC 11.2. Correspondence concerning implementation of this limitation and condition is docketed inReference 3.c.3. This limitation and condition relates to EPU applications and as such is not applicable to theM+SAR.4. The PRIME LTR and its application (Reference 3.a) was approved on January 22, 2010 andimplemented in GESTAR II in September 2010 (Reference 4). PRIME fuel parameters willbe used in all analyses requiring fuel performance parameters.
: 5. NMP2 uses GEl4 fuel, and as such does not seek to apply 10 wt.% Gd to this licensing application.
: 6. This limitation and condition relates to GEH's treatment of the NRC staff review of the10 CFR Part 21 report related to the GESTR-M T-M evaluation.
The NMP2 M+SAR has aPRIME T-M and PRIME fuel temperature basis included.
Therefore, this limitation is nolonger applicable.
: 7. The NMP2 M+SAR licensing basis is not based on TRACG for: (1) the void reactivity coefficient bias and uncertainties relative to lattice designs; (2) the void coefficient biasesand uncertainties for known dependencies; and (3) the Void-Quality Correlation.
The NMP2M+SAR analysis uses ODYN as the licensing basis code, and as such, this limitation andcondition is not applicable to the NMP2 M+SAR.8. The NMP2 M+SAR is not based on a mixed core, nor is it based on unapproved fuel productlines. NMP2 uses GE14, therefore, this limitation and condition is not applicable to theNMP2 M+SAR.9. If NMP2 is a first plant application of MELLLA+ then GEH will provide the requiredinformation.
This limitation and condition relates to a GEH commitment to submit cycle-specific eigenvalue tracking data to the NRC to establish performance of GEH methodsunder operation in the MELLLA+ operating domain. As such, this requirement specifies information to be supplied at a later date by GEH.10. In the event that the cycle specific reload analysis is based on TRACG rather than ODYN forAOO, no 0.01 adder to the OLMCPR is required.
A-16 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Appendix BDisposition of additional limitations and conditions related to the final SE forNEDC-33006P, "Maximum Extended Load Line Limit Analysis Plus"There are 54 limitations and conditions listed in Section 12 of the M+LTR SER. The tablebelow lists each of the 54 limitations and conditions.
The table also shows that NMP2 complieswith 47 of the limitations and conditions.
The table identifies which section of this M+SARdiscusses compliance with each limitation and condition.
The remaining seven limitations andconditions are not applicable to NMP2 for the following reasons.12.3d NMP2 MELLLA+ is not based on unapproved fuel product lines.12.3e NMP2 MELLLA+ is not based on unapproved fuel product lines.12.3f NMP2 MELLLA+ is not based on unapproved fuel product lines.12.1 O.c NMP2 MELLLA+ takes credit for off-rated limits at the minimum CFstatepoint.
Core monitoring is required.
12.20 NMP2 MELLLA+ is based on plant specific ATWS Instability (12.19).12.23.6 NMP2 MELLLA+ is not based on unapproved fuel product lines.12.23.7 NMP2 MELLLA+ is not based on unapproved fuel product lines.B-I NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Appendix B (continued)
Disposition of additional limitations and conditions related to the final SE forNEDC-33006P, "Maximum Extended Load Line Limit Analysis Plus"Limitation Section of NMP2Cnd Limitation and M+SAR whichnumber Condition Limitation and Condition Description Disposition addresses theNumberTitle Limitation andSER Condition The plant-specific application will confirm that foroperation within the boundary defined by theMELLLA+ upper boundary and maximum CFrange, the GEXL-PLUS experimental databasecovers the thermal-hydraulic conditions the fuelbundles will experience, including, bundle power,mass flux, void fraction,
: pressure, and subcooling.
If the GEXL-PLUS experimental database does notcover the within bundle thermal-hydraulic conditions, during steady-state, transient conditions, 12.1 GEXL-PLUS and DBA conditions, GHNE will inform the NRC Comply Sections 1.1.3 andat the time of submittal and obtain the necessary 2.6.4data for the submittal of the plant-specific MELLLA+ application.
In addition, the plant-specific application will confirm that theexperimental pressure drop database for thepressure drop correlation covers the pressure dropsanticipated in the MELLLA+ range.With subsequent fuel designs, the plant-specific applications will confirm that the databasesupporting the CPR correlations covers the powers,B-2 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Limitation Section of NMP2andCnd Limitation and M+SAR whichCondition Number Condition Limitation and Condition Description Disposition addresses thefrom NRC Title Limitation andSER Condition flows and void fractions BWR bundles willexperience for operation at and within theMELLLA+ domain, during steady-state, transient, and DBA conditions.
The plant-specific submittal will also confirm that the NRC staff reviewed andapproved the associated CPR correlation if thechanges in the correlation are outside theGESTAR I1 (Amendment
: 22) process.
Similarly, the plant-specific application will confirm that theexperimental pressure drop database does cover therange of pressures the fuel bundles will experience for operation within the MELLLA+ domain.Plant-specific MELLLA+ applications must complywith the limitations and conditions specified in and12.2 Related LTRs be consistent with the purpose and content covered Comply Section 1.0in the NRC staff SEs approving the latest version ofthe following LTRs: NEDC-33173P, NEDC-33075P-A, and NEDC-33147-A.
B-3 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Limitation Section of NMP2Cnd Limitation and M+SAR whichnumber Condition Limitation and Condition Description Disposition addresses thefrmbNr Title Limitation andSER Condition The plant-specific analyses supporting MELLLA+operation will include all operating condition changes that are implemented at the plant at thetime of MELLLA+ implementation.
Operating condition changes include, but are not limited to,those changes that affect, an increase in the domepressure, maximum CF, fuel cycle length, or anyConcurrent changes in the licensed operational enhancements.
Comply Section 1.1.2Changes For example, with an increase in dome pressure, thefollowing analyses must be analyzed:
the ATWSanalysis, the ASME overpressure
: analyses, thetransient
: analyses, and the ECCS-LOCA analysis.
Any changes to the safety system settings or anyactuation setpoint changes necessary to operatewith the increased dome pressure must be includedin the evaluations (e.g., SRV setpoints).
B-4 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Limitation Section of NMP2Cnd Limitation and M+SAR whichnumber Condition Limitation and Condition Description Disposition addresses thefrmbNr Title Limitation andfrom NRC Condition SERFor all topics in LTR NEDC-33006P that arereduced in scope or generically dispositioned, theplant-specific application will provide justification that the reduced scope or generic disposition isapplicable to the plant. If changes that invalidate 12.3.b the LTR dispositions are to be implemented at the Comply Section 1.1 1time of MELLLA+ implementation, theplant-specific application will provide analyses andevaluations that demonstrate the cumulative effectwith MELLLA+ operation.
For example, if thedome pressure is increased, the ECCS performance will be evaluated on a plant-specific basis.Any generic bounding sensitivity analyses providedin LTR NEDC-33006P will be evaluated to ensurethat the key plant-specific input parameters andassumptions are applicable and bounded.
If thesegeneric sensitivity analyses are not applicable oradditional operating condition changes affect the12.3.c generic sensitivity
: analyses, a plant-specific Comply Section 1.1.1evaluation will be provided.
For example, with anincrease in the dome pressure, the ATWSsensitivity analyses that model operator actions(e.g., depressurization if the HCTL is reached)needs to be reanalyzed, using the bounding domepressure condition.
B-5 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Limitation and Section of NMP2Cnd Limitation and M+SAR whichnumber Condition Limitation and Condition Description Disposition addresses thefrmbNr Title Limitation andSER Condition 12.3.dIf a new GE fuel product line or another vendor'sfuel is loaded at the plant, the applicability of anygeneric sensitivity analyses supporting theMELLLA+ application shall be justified in theplant-specific application.
If the generic sensitivity analyses cannot be demonstrated to be applicable, the analyses will be performed including the newfuel. For example, the ATWS instability analysessupporting the MELLLA+ condition are based onthe GEl4 fuel response.
New analyses thatdemonstrate the ATWS instability performance ofthe new GE fuel or another vendor's fuel forMELLLA+ operation shall be provided to supportthe plant-specific application.
N/ASection 2.0(1)12.3.eIf a new GE fuel product line or another vendor'sfuel is loaded at the plant prior to a MELLLA+application, the analyses supporting the plant-specific MELLLA+ application will be based on aspecific core configuration or bounding coreconditions.
Any topics that are generically dispositioned or reduced in scope in LTRNEDC-33006P will be demonstrated to beapplicable, or new analyses based on the specificcore configuration or bounding core conditions willbe provided.
N/ASection 2.0(1)B-6 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Limitation Section of NMP2and Limitation and M+SAR whichCondition Condition Limitation and Condition Description Disposition addresses theNumberfrmbNr Title Limitation andfrom NRC Condition SERIf a new GE fuel product line or another vendor'sfuel is loaded at the plant prior to a MELLLA+application, the plant-specific application willreference an NRC-approved stability methodsupporting MELLLA+ operation, or provide Section 2.012.3.f sufficient plant-specific information to allow the N/ANRC staff to review and approve the stability (1)method supporting MELLLA+ operation.
Theplant-specific application will demonstrate that theanalyses and evaluations supporting the stability method are applicable to the fuel loaded in the core.For MELLLA+ operation, core instability ispossible in the event a transient or plant maneuverplaces the reactor at a high power/low-flow condition.
Therefore, plants operating atMELLLA+ conditions must have a NRC-approved 12.3.g instability protection method. In the event theinstability protection method is inoperable, the Comply Section 2.4applicant must employ an NRC-approved backupinstability method. The licensee will provide TSchanges that specify the instability methodoperability requirements for MELLLA+ operation, including any BSP methods.The plant-specific MELLLA+ application shall12.4 Reload analysis provide the plant-specific thermal limits assessment Comply Sections 1.1.1 andsubmittal and transient analysis results.
Considering the 9.1.1timing requirements to support the reload, the fuelB-7 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Limitation Section of NMP2andCnd Limitation and M+SAR whichnumber Condition Limitation and Condition Description Disposition addresses theNumberfrom NRC Title Limitation andSER Condition and cycle-dependent analyses including the plant-specific thermal limits assessment may besubmitted by supplementing the initial M+SAR.Additionally, the SRLR for the initial MELLLA+implementation cycle shall be submitted for NRCstaff confirmation.
The licensee will amend the TS LCO for any EOOS Sections 1.1.1 and12.5.a (i.e., SLO) or operating flexibilities prohibited in Comply 1.2.4the plant-specific MELLLA+ application.
For an operating flexibility, such as Feedwater Heater(s)
Out-of-Service (FWHOOS),
that is12.5.b prohibited in the MELLLA+ plant-specific application but is not included in the TS LCO, the Comply Section 1.2.4licensee will propose and implement a licenseOperating condition.
Flexibility The power flow map is not specified in the TS;however, it is an important licensed operating domain. Licensees may elect to be licensed andoperate the plant under plant-specific-expanded 12.5.c domain that is bounded by the MELLLA+ upper Comply Section 1.2.1boundary.
Plant-specific applications approved foroperation within the MELLLA+ domain willinclude the plant-specific power/flow mapspecifying the licensed domain in the COLR.SLMCPR Until such time when the SLMCPR methodology 12.6 Statepoints and (References 10 and 25) for off-rated SLMCPR Comply Section 2.2.1CF Uncertainty calculation is approved by the staff for MELLLA+B-8 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Limitation Section of NMP2andCnd Limitation and M+SAR whichnumber Condition Limitation and Condition Description Disposition addresses thefrmbNr Title Limitation andfrom NRC Condition SERoperation, the SLMCPR will be calculated at therated statepoint (120 percent P/100 percent CF), theplant-specific minimum CF statepoint (e.g., 120 percent P /80 percent CF), and at the100 percent OLTP at 55 percent CF statepoint.
Thecurrently approved off-rated CF uncertainty will beused for the minimum CF and 55 percent CFstatepoints.
The uncertainty must be consistent with the CF uncertainty currently applied to theSLO operation or as NRC-approved for MELLLA+operation.
The calculated values will bedocumented in the SRLR.Manual operator actions are not adequate to controlthe consequences of instabilities when operating inthe MELLLA+ domain. If the primary stability protection system is declared inoperable, a non-12.7 Stability manual NRC-approved backup protection system Comply Section 2.4must be provided, or the reactor core must beoperated below a NRC-approved backup stability boundary specifically approved for MELLLA+operation for the stability option employed.
B-9 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Limitation Section of NMP2andCnd Limitation and M+SAR whichnumber Condition Limitation and Condition Description Disposition addresses thefrmbNr Title Limitation andSER Condition The applicant is to provide a plant-specific Fluence evaluation of the MELLLA+ RPV fluence using the8 Methodology most up-to-date NRC-approved fluence12.8 and Fracture methodology.
This fluence will then be used to Comply Section 3.2.1Toughness provide a plant-specific evaluation of the RPVfracture toughness in accordance with RG 1.99,Revision 2 (Reference 57).MELLLA+ applicants must identify all other thanReactor Category "A" materials, as defined in12.9 Coolant NUREG-0313 (Reference 20), Revision 2, thatPressure exist in its RCPB piping, and discuss the adequacy Comply Section 3.5.1.4Boundary of the augmented inspection programs in light ofthe MELLLA+ operation on a plant-specific basis.B-10 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Limitation Section of NMIP2andCnd Limitation and M+SAR whichnumber Condition Limitation and Condition Description Disposition addresses thefrmbNr Title Limitation andfrom NRC Condition SERThe plant-specific application will provide the10 CFR Part 50, Appendix K, and the nominalPCTs calculated at the rated EPU power/rated CF,rated EPU power/minimum CF, at the low-flowMELLLA+ boundary (Transition Statepoint).
Forthe limiting statepoint, both the upper bound andthe licensing PCT will be reported.
The M+SARwill justify why the transition statepoint ECCO -Ca ECCS-LOCA response bounds the 55 percent CF Comply Section 4.3.212.10.a Off-rated statepoint.
The M+SAR will provide discussion onMultiplier what power/flow combination scoping calculations were performed to identify the limiting statepoints in terms of DBA-LOCA PCT response for theoperation within the MELLLA+ boundary.
TheM+SAR will justify that the upper bound andlicensing basis PCT provided is in fact the limitingPCT considering uncertainty applications to thenon-limiting statepoints.
B-il NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Limitation Section of NMP2andCnd Limitation and M+SAR whichnumber Condition Limitation and Condition Description Disposition addresses thefrmbNr Title Limitation andSER Condition LOCA analysis is not performed on cycle-specific basis; therefore, the thermal limits applied in theM+SAR LOCA analysis for the 55 percent CFMELLLA+ statepoint and/or the transition statepoint must be either bounding or consistent with cycle-specific off-rated limits. The COLR andthe SRLR will contain confirmation that the off- Sections 4.3.2 and12.10.b rated limits assumed in the ECCS-LOCA analyses Comply 4.3.3bound the cycle-specific off-rated limits calculated for the MELLLA+ operation.
Every future cyclereload shall confirm that the cycle-specific off-rated thermal limits applied at the 55 percent CF and/orthe transition statepoints are consistent with thoseassumed in the plant-specific ECCS-LOCA analyses.
: 12. 1 Ox Off-rated limits will not be applied to the minimum N/A (2)CF statepoint.
If credit is taken for these off-rated limits, the plant12.0 O.d will be required to apply these limits during core Comply Section 4.3.21 monitoring.
B-12 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Limitation Section of NMP2Cnd Limitation and M+SAR whichnumber Condition Limitation and Condition Description Disposition addresses thefrmbNr Title Limitation andSER Condition For MELLLA+ applications, the small and largebreak ECCS-LOCA analyses will include top-ECCS-LOCA peaked and mid-peaked power shape in establishing 12.11 Axial Power the MAPLHGR and determining the PCT. This Comply Sections 4.3.2 andDistribution limitation is applicable to both the licensing bases 4.3.3Evaluation PCT and the upper bound PCT. The plant-specific applications will report the limiting small and largebreak licensing basis and upper bound PCTs.12. 12.a Both the nominal and Appendix K PCTs should be Comply Section 4.3.3reported for all of the calculated statepoints, andThe plant-variable and uncertainties currently Reporting applied will be used, unless the NRC staff12.12.b specifically approves a different plant variable Comply Section 4.3.3uncertainty method for application to the non-rated statepoints.
Small break LOCA analysis will be performed atthe MELLLA+ minimum CF and the transition Small Break statepoints for those plants that: (1) are small break12.13 LOCA LOCA limited based on small break LOCA analysis Comply Section 4.3.3performed at the rated EPU conditions; or (2) havemargins of less than or equal to [[ ]] relativeto the Appendix K or the licensing basis PCT.B-13 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Limitation Section of NMP2Cnd Limitation and M+SAR whichnumber Condition Limitation and Condition Description Disposition addresses therTitle Limitation andfrom NRC TitleSER Condition The scope of small break LOCA analysis forMELLLA+ operation relies upon the EPU smallBreak break LOCA analysis results.
Therefore, the NRC12.14 Spectrum staff concludes that for plants that will implement Comply Section 4.3.1MELLLA+,
sufficient small break sizes should beanalyzed at the rated EPU power level to ensurethat the peak PCT break size is identified.
Plant-specific MELLLA+ applications shallidentify where in the MELLLA+ upper boundarythe bypass voiding greater than 5 percent will occurabove the D-level.
The licensee shall provide in theplant-specific submittal the operator actions andBypass Voiding procedures that will mitigate the effect of the12.15 Above the D- bypass voiding on the TIPs and the core simulator Comply Section 5.1.5Abve used to monitor the fuel performance.
Theplant-specific submittal shall also providediscussion on what effect the bypass voiding greaterthan 5 percent will have on the NMS as defined inSection 5.1.1.5.
The NRC staff will evaluate onplant-specific bases acceptability of bypass voidingabove D level.Plants operating at the MELLLA+ operating domain shall perform RWE analyses to confirm the12.16 RWE adequacy of the generic RBM setpoints.
The Comply Section 9.1.1M+SAR shall provide a discussion of the analyses_performed and the results.B-14 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Limitation Section of NMP2Cnd Limitation and M+SAR whichnumber Condition Limitation and Condition Description Disposition addresses therTitle Limitation andfrom NRC TitleSER Condition As specified in LTR NEDC-33006P, at least twoplant-specific ATWS calculations must beperformed:
MSIVC and PRFO. In addition, if RHRcapability is affected by LOOP, then a thirdplant-specific ATWS calculation must beperformed that includes the reduced RHRcapability.
To evaluate the effect of reduced RHRcapacity during LOOP, the plant-specific ATWS12.17 ATWS LOOP calculation must be performed for a sufficiently Comply Section 9.3.1.1large period of time after HSBW injection iscomplete to guarantee that the suppression pooltemperature is cooling, indicating that the RHRcapacity is greater than the decay heat generation.
The plant-specific application should includeevaluation of the safety system performance duringthe long-term cooling phase, in terms of available NPSH.For plants that do not achieve hot shutdown prior toreaching the HCTL based on the licensing ODYNATWS code calculation, plant-specific MELLLA+12.18.a TRACG implementations must perform best-estimate TRACG calculations on a plant-specific basis. The Comply Section 9.3.1.2Analysis TRACG analysis will account for all plantparameters, including water-level control strategyand all plant-specific EOP actions.B-15 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Limitation Section of NMP2andCnd Limitation and M+SAR whichnumber Condition Limitation and Condition Description Disposition addresses thefrmbNr Title Limitation andSER Condition The TRACG calculation is not required if the plantincreases the boron- 10 concentration/enrichment so12.18.b that the integrated heat load to containment Comply Sections 9.3.1.1 andcalculated by the licensing ODYN calculation does 9.3.1.2not change with respect to a reference OLTP/75 percent flow ODYN calculation.
PCT for both phases of the transient (initial12.18.c overpressure and emergency depressurization) must Comply Section 9.3.1.2be evaluated on a plant-specific basis with theTRACG ATWS calculation.
B-16 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Limitation Section of NMP2andCondition Limitation and M+SAR whichNumber Condition Limitation and Condition Description Disposition addresses themTitle Limitation andfrom NRC TitleioSER Condition In general, the plant-specific application will ensurethat operation in the MELLLA+ domain isconsistent with the assumptions used in the ATWSanalysis, including EOOS (e.g., FWHOOS, SLO,SRVs, SLS pumps, and RHR pumps, etc.). Ifassumptions are not satisfied, operation inMELLLA+ is not allowed.
The SRLR will specifythe prohibited flexibility options for plant-specific MELLLA+ operation, where applicable.
For keyinput parameters, systems and engineering safety12.18.d features that are important to simulating the ATWS Comply Section 9.3.1.1analysis and are specified in the TS (e.g., SLSparameters, ATWS RPT, etc.), the calculation assumptions must be consistent with the allowed TSvalues and the allowed plant configuration.
If theanalyses deviate from the allowed TS configuration for long-term equipment out- of-service (i.e., beyond the TS LCO), the plant-specific application will specify and justify the deviation.
Inaddition, the licensee must ensure that alloperability requirements are met (e.g., NPSH) byequipment assumed operable in the calculations.
B-17 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Limitation Section of NMP2andCnd Limitation and M+SAR whichnumber Condition Limitation and Condition Description Disposition addresses thefrmbNr Title Limitation andfrom NRC Condition SERNominal input parameters can be used in theATWS analyses provided the uncertainty treatment and selection of the values of these inputparameters are consistent with the input methodsused in the original GE ATWS analyses in12.18.e NEDE-24222.
Treatment of key input parameters Comply Section 9.3.1in terms of uncertainties applied or plant-specific TS value used can differ from the originalNEDE-24222
: approach, provided the manner inwhich it is used yields more conservative ATWSresults.The plant-specific application will include12.18.f tabulation and discussion of the key input Comply Section 9.3.1parameters and the associated uncertainty treatment.
B-18 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Limitation Section of NMP2and Limitation and M+SAR whichCondition Lmtto nnumber Condition Limitation and Condition Description Disposition addresses thefrmbNr Title Limitation andfrom NRC Condition SERUntil such time that NRC approves a genericsolution for ATWS instability calculations forMELLLA+ operation, each plant-specific MELLLA+ application must provide ATWSinstability analysis that satisfies the ATWSacceptance criteria listed in SRP Section 15.8. Theplant-specific ATWS instability calculation must:Plant-Specific (1) be based on the peak-reactivity exposure12.19 ATWS conditions, (2) model the plant-specific Comply Section 9.3.3Instability configuration important to ATWS instability response including mixed core, if applicable, and(3) use the regional-mode nodalization scheme. Inorder to improve the fidelity of the analyses, theplant-specific calculations should be based on latestNRC-approved neutronic and thermal-hydraulic codes such as TGBLA06/PANAC 11 andTRACG04.B-19 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Limitation Section of NMP2andCnd Limitation and M+SAR whichnumber Condition Limitation and Condition Description Disposition addresses therTitle Limitation andfrom NRC Condition SEROnce the generic solution is approved, the plant-specific applications must provide confirmation thatthe generic instability analyses are relevant andapplicable to their plant. Applicability confirmation includes review of any differences in plant designor operation that will result in significantly lowerstability margins during ATWS such as:12.20 Generic ATWS
* turbine bypass capacity, N/A (3)Instability 0 fraction of steam-driven feedwater pumps,9 any changes in plant design or operation thatwill significantly increase core inlet subcooling during ATWS events,* significant differences in radial and axialpower distributions, o hot-channel power-to-flow ratio,0 fuel design changes beyond GE14.B-20 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Limitation Section of NMP2andCnd Limitation and M+SAR whichnumber Condition Limitation and Condition Description Disposition addresses thefrmbNr Title Limitation andfrom NRC Condition SERLicensees that submit a MELLLA+ application should address the plant-specific risk effectsassociated with MELLLA+ implementation, consistent with approved guidance documents (e.g., NEDC-32424P-A, NEDC-32523P-A, andIndividual Plant NEDC-33004P-A) and the Matrix 13 of RS-00112.21 Evaluation and re-address the plant-specific risk effects Comply Section 10.5consistent with the approved guidance documents that were used in their approved EPU application and Matrix 13 ofRS-001.
If an EPU andMELLLA+ application come to the NRC inparallel, the expectation is that the EPU submittal will have incorporated the MELLLA+ effects.The applicant is to provide a plant-specific IASCCevaluation when implementing MELLLA+,
whichincludes the components that will exceed theIASCC threshold of 5xl 020 n/cm2 (E> 1MeV), theeffect of failure of these components on the12.22 IASCC integrity of the reactor internals and core support Comply Section 10.7.1structures under licensing design bases conditions, and the inspections that will be performed oncomponents that exceed the IASCC threshold toensure timely identification of IASCC, should itoccur.Limitations Section 9.3.1.112.23.1 from the See limitation 12.18.d.
ComplyATWS RAI (4)B-21 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Limitation Section of NM.P2andCnd Limitation and M+SAR whichnumber Condition Limitation and Condition Description Disposition addresses therTitle Limitation andfrom NRC Condition SEREvaluations The plant-specific ODYN and TRACG key12.23.2 calculation parameters must be provided to the staff Comply Sections 1.1.3 andso they can verify that all plant-specific automatic 9.3.1settings are modeled properly.
The ATWS peak pressure response would bedependent upon SRVs upper tolerances assumed inthe calculations.
For each individual SRV, thetolerances used in the analysis must be consistent with or bound the plant-specific SRV performance.
The SRV tolerance test data would be statistically treated using the NRC's historical 95/95 approach12.23.3 or any new NRC-approved statistical treatment Comply Section 9.3.1.1method. In the event that current EPU experience base shows propensity for valve drift higher thanpre-EPU experience base, the plant-specific transient and ATWS analyses would be based onthe higher tolerances or justify the reason why thepropensity for the higher drift is not applicable theplant's SRVs.EPG/SAG parameters must be reviewed forapplicability to MELLLA+ operation in a plant-12.23.4 specific basis. The plant-specific MELLLA+ Sections 9.3.1.1 andapplication will include a section that discusses the Comply 10.9.1plant-specific EOPs and confirms that the ATWScalculation is consistent with the operator actions.B-22 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Limitation Section of NMP2andCnd Limitation and M+SAR whichnumber Condition Limitation and Condition Description Disposition addresses thefrmbNr Title Limitation andSER Condition The conclusions of this LTR and associated SE arelimited to reactors operating with a power densitylower than 52.5 MW/MLBM/hr for operation at the Sections 1.2.3 and12.23.5 minimum allowable CF at 120 percent OLTP. Comply 9.3.3Verification that reactor operation will bemaintained below this analysis limit must beperformed for all plant-specific applications.
For MELLLA+ applications involving GE fueltypes beyond GE 14 or other vendor fuels, bounding Section 2.012.23.6 ATWS Instability analysis will be provided to the N/Astaff. Note: this limitation does not apply to (1)special test assemblies.
Section 2.012.23.7 See limitation 12.23.6.
N/A(1)(5)The plant-specific ATWS calculations must account12.23.8 for all plant- and fuel-design-specific
: features, such Comply Section 9.3.1as the debris filters.B-23 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Limitation Section of NMP2Limitation and M+SAR whichCondition Condition Limitation and Condition Description Disposition addresses theNumberfrmbNr Title Limitation andfrom NRC Condition SERPlant-specific applications must review the safetysystem specifications to ensure that all of theassumptions used for the ATWS SE indeed apply totheir plant-specific conditions.
The NRC staffreview will give special attention to crucial safety12.23.9 systems like HPCI, and physical limitations likeNPSH and maximum vessel pressure that RCIC and Comply Section 4.2.6HPCI can inject. The plant-specific application willinclude a discussion on the licensing bases of theplant in terms of NPSH and system performance.
Itwill also include NPSH and system performance evaluation for the duration of the event.Plant-specific applications must ensure that anincrease in containment pressure resulting from12.23.10 ATWS events with EPU/MELLLA+
operation does Comply Section 9.3.1.1not affect adversely the operation of safety-grade equipment.
The plant-specific applications must justify the useof plant-specific suppression pool temperature 12.23.11 limits for the ODYN and TRACG calculations that Comply Section 9.3.1.1are higher than the HCTL limit for emergency
_depressurization.
B-24 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Section of NMP2Limitation and M+SAR whichCondition Limitation and Condition Description Disposition addresses theTitle Limitation andCondition For EPU/MELLLA+
plant-specific applications that use TRACG or any code that has the capability Comply Sections 2.6.2 andto model in-channel water rod flow, the supporting 9.3.3analysis will use the actual flow configuration.
Limitations The EPU/MELLLA+
application would provide thefrom Fuel exit void fraction of the high-powered bundles inDependent the comparison between the EPU/MELLLA+
and Comply Section 2.1.2Analyses RAI the pre-MELLLA+
conditions.
Evaluations Section 2.2.1See limitation 12.6. Comply(6)See limitation 12.18.d.
Comply (7)B-25 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Appendix B (Continued)
Disposition of additional limitations and conditions related to the final SE forNEDC-33006P, "Maximum Extended Load Line Limit Analysis Plus"Notes:1. NMP2 uses GE14 fuel, therefore, this limitation and condition is not applicable to the NMP2M+SAR.2. Because NMP2 takes credit for off-rated condition at the minimum CF statepoint, theM+LTR requires implementation of Limitation and Condition 12.10.d.
Therefore, Limitation and Condition 12.1 O.c is not applicable.
: 3. This requirement relates to implementation of a generic ATWS Instability
: Solution, which isnot yet approved by the NRC. NMP2 MELLLA+ is based on a plant-specific ATWSinstability analysis.
: 4. This is a repeat of Limitation and Condition 12.18.d.5. This is a repeat of Limitation and Condition 12.23.6.6. This is a repeat of Limitation and Condition 12.6.7. This is a repeat of Limitation and Condition 12.18.d.B-26 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Appendix CDisposition of additional limitations and conditions related to the draft SE for NEDC-33075P, Revision 7, "General Electric Boiling Water Reactor Detect and Suppress Solution
-Confirmation Density"There are four limitations and conditions listed in Section 5 of the DSS-CD LTR SER. The tablebelow lists each of the four limitations and conditions.
The table also shows that NMP2complies with all four of the limitations and conditions.
The table identifies which section ofthis M+SAR discusses compliance with each limitation and condition.
C-I NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Appendix C (continued)
Disposition of additional limitations and conditions related to the draft SE for NEDC-33075P, Revision 7, "General Electric BoilingWater Reactor Detect and Suppress Solution
-Confirmation Density"Limitation and Section of NMP2 M+SARCondition Limitation and Condition Description Disposition which addresses the Limitation Numberfrom NRC and Condition SERThe NRC staff previously reviewed and approvedthe implementation of DSS-CD using the approvedGEH Option III hardware and software.
TheDSS-CD solution is not approved for use withnon-GEH hardware.
The hardware components Section 2.45.1 required to implement DSS-CD are expected to be Complythose currently used for the approved Option III. If (1)the DSS-CD hardware implementation deviatesfrom the approved Option III solution, a hardwarereview by the NRC staff will be required.
Implementations on other Option III platforms willrequire plant-specific reviews.The CDA setpoint calculation formula and theadjustable parameters values are defined inNEDC-33075P, Revision 7 (Reference 2).Deviation from the stated values or calculation formulas is not allowed without NRC review. To Scin245.2 this end, the subject TR, when approved and Complyimplemented by a licensed nuclear power plant, (2)must be referenced in the plant TSs, so that thesevalues become controlled and part of the licensing bases.C-2 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Limitation andCondition Section of NMP2 M+SARNditio Limitation and Condition Description Disposition which addresses the Limitation from NRC and Condition SERThe NRC staff previously concluded that theplant-specific settings for eight of the FIXEDparameters and three of the ADJUSTABLE 53 parameters, as stated in section 3.6.3 of the NRC Comply (3)staff's SE for NEDC-33075P, Revision 5(Reference 58), are licensing basis values. Theprocess by which these values will be controlled must be addressed by licensees.
If plants other than Brunswick Steam Electric Plant,Units 1 and 2, use the DSS-CD trip function, those5.4 plant licensees must ensure the DSS-CD tripfunction is applicable in their plant licensing bases, Comply (4)including the optional BSP trip function, if it is tobe installed.
C-3 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION
-CLASS I (PUBLIC)Appendix C (continued)
Disposition of additional limitations and conditions related to the draft SE for NEDC-33075P, Revision 7, "General Electric Boiling Water Reactor Detect and Suppress Solution
-Confirmation Density"Notes:1. The DSS-CD solution is implemented on GEH hardware that is currently installed andapproved by the NRC for the Option III solution.
: 2. The subject TR, or GESTAR II, is referenced in the NMP2 TSs.3. The values of the FIXED and ADJUSTABLE parameters are established by GEH and will bedocumented in a DSS-CD Settings Report.4. Verification and validation (V&V) of the DSS-CD trip function code was performed fortransportability considerations.
C4}}

Revision as of 16:39, 3 July 2018

Attachment 8 - NEDC-33576NP, Safety Analysis Report for Nine Mile Point Unit 2 Maximum Extended Load Line Limit Analysis Plus (Non-proprietary)
ML13316B109
Person / Time
Site: Nine Mile Point Constellation icon.png
Issue date: 11/01/2013
From:
Constellation Energy Nuclear Group, EDF Group, Nine Mile Point
To:
Office of Nuclear Reactor Regulation
Shared Package
ML13316B090 List:
References
DRF Section 0000-0138-0146, Rev. 6, NEDO-33576, Rev. 0
Download: ML13316B109 (257)


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{{#Wiki_filter:ATTACHMENT 8NEDC-33576NP, SAFETY ANALYSIS REPORT FORNINE MILE POINT UNIT 2MAXIMUM EXTENDED LOAD LINE LIMIT ANALYSIS PLUS(NON-PROPRIETARY) Nine Mile Point Nuclear Station, LLCNovember 1, 2013 0HITACHIGE Hitachi Nuclear EnergyNEDO-33576 Revision 0DRF Section 0000-0138-0146 R6October 2013Non-Proprietary Information -Class I (Public)Safety Analysis ReportforNine Mile Point Unit 2Maximum Extended Load Line Limit Analysis PlusCopyright 2013 GE-Hitachi Nuclear Energy Americas LLCAll Rights Reserved NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)INFORMATION NOTICEThis is a non-proprietary version of the document NEDC-33576P, Revision 0, which has theproprietary information removed. Portions of the document that have been removed areindicated by an open and closed bracket as shown here [[IMPORTANT NOTICE REGARDING CONTENTS OF THIS REPORTPlease Read Carefully The design, engineering, and other information contained in this document is furnished for thepurposes of supporting the Constellation Energy Nuclear Group (CENG) license amendment request for a Maximum Extended Load Line Limit Analysis Plus at Nine Mile Point Unit 2 inproceedings before the U.S. Nuclear Regulatory Commission. The only undertakings of GEHwith respect to information in this document are contained in the contracts between GEH and itscustomers or participating utilities, and nothing contained in this document shall be construed aschanging that contract. The use of this information by anyone for any purpose other than that forwhich it is intended, is not authorized; and with respect to any unauthorized use, GEH makes norepresentation or warranty, and assumes no liability as to the completeness,

accuracy, orusefulness of the information contained in this document.

ii NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)TABLE OF CONTENTSPageExecutive Sum m ary ..................................................................................................................... ixA cronym s ...................................................................................................................................... xi1.0 Introduction .................................................................................................................... 1-11.1 Report Approach ........................................................................................................... 1-21.2 Operating Conditions and Constraints ........................................................................... 1-71.3 Sum m ary and Conclusions ............................................................................................ 1-92.0 Reactor C ore and Fuel Perform ance ........................................................................... 2-12.1 Fuel Design and Operation ............................................................................................ 2-12.2 Therm al Lim its A ssessm ent .......................................................................................... 2-32.3 Reactivity Characteristics .............................................................................................. 2-62.4 Stability .......................................................................................................................... 2-82.5 Reactivity Control ....................................................................................................... 2-142.6 Additional Limitations and Conditions Related to Reactor Core and FuelPerform ance ............................................................................................................ 2-153.0 Reactor C oolant and C onnected System s .................................................................... 3-13.1 N uclear System Pressure Relief and Overpressure Protection ...................................... 3-13.2 Reactor Vessel ............................................................................................................... 3-23.3 Reactor Internals ............................................................................................................ 3-33.4 Flow -Induced V ibration .............................................................................................. 3-103.5 Piping Evaluation ........................................................................................................ 3-133.6 Reactor Recirculation System ..................................................................................... 3-203.7 M ain Steam Line Flow Restrictors .............................................................................. 3-223.8 M ain Steam Isolation Valves ....................................................................................... 3-233.9 Reactor Core Isolation Cooling ................................................................................... 3-233.10 Residual Heat Rem oval System .................................................................................. 3-253.11 Reactor W ater Cleanup System ................................................................................... 3-264.0 Engineered Safety Features .......................................................................................... 4-14.1 Containm ent System Perform ance ................................................................................ 4-14.2 Em ergency Core Cooling System s ................................................................................ 4-64.3 Em ergency Core Cooling System Perform ance .......................................................... 4-104.4 M ain Control Room A tm osphere Control System ...................................................... 4-174.5 Standby G as Treatm ent System ................................................................................... 4-174.6 M ain Steam Isolation Valve Leakage Control System ................................................ 4-184.7 Post-LO CA Com bustible G as Control System ........................................................... 4-185.0 Instrum entation and C ontrol ........................................................................................ 5-15.1 N SSS M onitoring and Control ...................................................................................... 5-15.2 BO P M onitoring and Control ........................................................................................ 5-35.3 Technical Specification Instrum ent Setpoints ............................................................... 5-6iii NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)6.0 Electrical Pow er and A uxiliary System s ...................................................................... 6-16.1 A C Pow er ...................................................................................................................... 6-I6.2 D C Pow er ...................................................................................................................... 6-16.3 Fuel Pool ........................................................................................................................ 6-26.4 W ater System s ............................................................................................................... 6-36.5 Standby Liquid Control System .................................................................................... 6-46.6 H eating, Ventilation And A ir Conditioning .................................................................. 6-66.7 Fire Protection ............................................................................................................... 6-66.8 Other System s A ffected ................................................................................................. 6-77.0 Pow er C onversion System s ........................................................................................... 7-17.1 Turbine-G enerator ......................................................................................................... 7-17.2 Condenser and Steam Jet A ir Ejectors .......................................................................... 7-17.3 Turbine Steam Bypass ................................................................................................... 7-27.4 Feedw ater and Condensate System s .............................................................................. 7-28.0 R adw aste System s and Radiation Sources .................................................................. 8-18.1 Liquid and Solid W aste M anagem ent ........................................................................... 8-18.2 G aseous W aste M anagem ent ......................................................................................... 8-18.3 Radiation Sources in the Reactor Core .......................................................................... 8-38.4 Radiation Sources in Reactor Coolant ........................................................................... 8-38.5 Radiation Levels ............................................................................................................ 8-48.6 N orm al O peration O ff-Site D oses ................................................................................. 8-69.0 R eactor Safety Perform ance Evaluations .................................................................... 9-19.1 Anticipated Operational O ccurrences ............................................................................ 9-19.2 Design Basis Accidents and Events of Radiological Consequence .............................. 9-49.3 Special Events ............................................................................................................. 9-1010.0 O ther Evaluations ........................................................................................................ 10-110.1 H igh Energy Line Break .............................................................................................. 10-110.2 M oderate Energy Line Break ...................................................................................... 10-210.3 Environm ental Q ualification ....................................................................................... 10-310.4 Testing ......................................................................................................................... 10-510.5 Individual Plant Exam ination ...................................................................................... 10-610.6 Operator Training and Hum an Factors ...................................................................... 10-1110.7 Plant Life ................................................................................................................... 10-1210.8 N RC and Industry Com m unications ......................................................................... 10-1510.9 Em ergency and Abnorm al Operating Procedures ..................................................... 10-1511.0 Licensing Evaluations .................................................................................................. 11-111.1 Effect on Technical Specifications .............................................................................. 11-111.2 Environm ental A ssessm ent ......................................................................................... 11-111.3 Significant Hazards Consideration A ssessm ent .......................................................... 11-212.0 R eferences ..................................................................................................................... 12-1iv NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Appendix A ............................................................................................................................ A -1Appendix B ............................................................................................................................. B-1A ppendix C ............................................................................................................................. C-1V NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)List of FiguresFigure Title PageFigure 1-1 Power/Flow Operating Map for MELLLA+ ........................................................ 1-14Figure 2-1 Power of Peak Bundle versus Cycle Exposure ..................................................... 2-22Figure 2-2 Coolant Flow for Peak Bundle versus Cycle Exposure ........................................ 2-23Figure 2-3 Exit Void Fraction for Peak Power Bundle versus Cycle Exposure ..................... 2-24Figure 2-4 Maximum Channel Exit Void Fraction versus Cycle Exposure ........................... 2-25Figure 2-5 Core Average Exit Void Fraction versus Cycle Exposure .................................... 2-26Figure 2-6 Peak LHGR versus Cycle Exposure ..................................................................... 2-27Figure 2-7 Dimensionless Bundle Power at BOC (200 MWd/ST) ........................................ 2-28Figure 2-8 Dimensionless Bundle Power at MOC (10,000 MWd/ST) .................................. 2-29Figure 2-9 Dimensionless Bundle Power at EOC (18,577 MWd/ST) .................................... 2-30Figure 2-10 Bundle Operating LHGR (kW/ft) at BOC (200 MWd/ST) .................................. 2-31Figure 2-11 Bundle Operating LHGR (kW/ft) at MOC (10,000 MWd/ST) ............................ 2-32Figure 2-12 Bundle Operating LHGR (kW/ft) at EOC (18,577 MWd/ST) ............................. 2-33Figure 2-13 Bundle Operating MCPR at BOC (200 MWd/ST) ............................................... 2-34Figure 2-14 Bundle Operating MCPR at MOC (10,000 MWd/ST) ......................................... 2-35Figure 2-15 Bundle Operating MCPR at EOC (18,577 MWd/ST) .......................................... 2-36Figure 2-16 Bundle Operating LHGR (kW/ft) at 15,000 MWd/ST (Peak MFLPD Point) ...... 2-37Figure 2-17 Bundle Operating MCPR at 1,500 MWd/ST (Peak MFLCPR Point) .................. 2-38Figure 2-18 Bundle Average Void History for Bundles with Low CPRs ................................ 2-39Figure 2-19 Required OPRM Arm ed Region ........................................................................... 2-40Figure 5-1 NMP2 EPU/M+ Power/Flow Map with 5% Voiding at the TIP ExitB ou n d ary ................................................................................................................ 5-9Figure 9-1 L R N B P at IC F ...................................................................................................... 9-26Figure 9-2 LRN BP at M ELLLA+ .......................................................................................... 9-27Figure 9-3 ODYN ATWS Analysis -PRFO at EOC Short-Term Results ............................ 9-28Figure 9-4 ODYN ATWS Analysis -MSIVC at EOC Long-Term Results .......................... 9-29Figure 9-5 ODYN ATWS Analysis -PRFO at EOC PCT .................................................... 9-30Figure 9-6 Single SLS Pump ODYN ATWS Analysis -PRFO at EOC Short-Term R e su lts .................................................................................................................. 9 -3 1Figure 9-7 Single SLS Pump ODYN ATWS Analysis -MSIVC at EOC Long-Term R e su lts .................................................................................................................. 9 -3 2Figure 9-8 Single SLS Pump ODYN ATWS Analysis -PRFO at EOC PCT ....................... 9-33Figure 9-9 ATWS Instability from MELLLA+ Operating Domain -Turbine Trip withF u ll B yp ass ........................................................................................................... 9-34vi NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Figure 9-10 ATWS Instability from MELLLA+ Operating Domain -Turbine Trip withF u ll B yp ass ........................................................................................................... 9-35Figure 9-11 ATWS Instability from MELLLA+ Operating Domain -Recirculation P u m p T rip ............................................................................................................. 9-36Figure 9-12 ATWS Instability from MELLLA+ Operating Domain -Recirculation P u m p T rip ............................................................................................................. 9-37vii NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)List of TablesTable Title PageTable 1-1 Computer Codes Used in the M+SAR Evaluations .............................................. 1-10Table 1-3 Core Thermal Power to Core Flow Ratios ............................................................ 1-13Table 2-1 Peak N odal Exposures .......................................................................................... 2-17Table 2-2 Core Thermal Power to Core Flow Ratio at Steady-State and Off-Rated C o n d itio n s ............................................................................................................ 2 -18Table 2-3 TLO and SLO DSS-CD Licensing Basis Generic Applicability EnvelopeC hecklist C onfirm ation ........................................................................................ 2-19Table 2-4 [[................. 2-20Table 2-5 [[]].................................................................................................... 2 -2 1Table 3-1 K ey Results at 120% O LTP .................................................................................. 3-29Table 9-1 A OO Event Results Sum m ary .............................................................................. 9-17Table 9-2 Comparison of Slow Recirculation Flow Increase Results and MCPR FlowL im it ..................................................................................................................... 9 -18Table 9-3 Key Input Parameters for ATWS Analyses .......................................................... 9-19Table 9-4 Key Results for Licensing Basis ODYN ATWS Analysis ................................... 9-20Table 9-5 ODYN ATWS Analysis Limiting Event Results at MELLLA+ .......................... 9-21Table 9-6 Key Input Parameters for Single SLS Pump ATWS Analyses ............................. 9-22Table 9-7 Key Results for Single SLS Pump ODYN ATWS Analysis ................................ 9-23Table 9-8 Single SLS Pump ODYN ATWS Analysis Limiting Event Results .................... 9-24Table 9-9 Key Results for ATWS with Core Instability Analysis from MELLLA+O perating D om ain ................................................................................................ 9-25viii NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)EXECUTIVE SUMMARYThis report summarizes the results of all significant safety evaluations (SEs) performed thatjustify the expansion of the core flow (CF) operating domain for the Nine Mile Point Unit 2(NMP2) nuclear plant. The changes expand the operating domain in the region of operation withless than rated core flow (RCF), but do not increase the licensed power level or the maximumCF. The expanded operating domain is identified as Maximum Extended Load Line LimitAnalysis Plus (MELLLA+). The scope of evaluations required to support the expansion of the CF operating domain to theMELLLA+ boundary is contained in the Licensing Topical Report (LTR) NEDC-33006P-A, "Maximum Extended Load Line Limit Analysis Plus," referred to as the M+LTR (Reference 1).This report provides a systematic disposition of the M+LTR subjects applied to NMP2, including performance of plant-specific assessments and confirmation of the applicability of genericassessments to support a MELLLA+ CF operating domain expansion. It is not the intent of this report to address all the details of the analyses and evaluations reportedherein. Only previously Nuclear Regulatory Commission (NRC)-approved or industry-accepted methods were used for the analyses of accidents and transients. Therefore, because the safetyanalysis methods have been previously addressed, the details of the methods are not presented for review and approval in this report. Also, event and analysis descriptions that are alreadyprovided in other licensing reports or the updated safety analysis report (USAR) are not repeatedwithin this report.The MELLLA+ operating domain expansion is applied as an incremental expansion of theoperating boundary without changing the maximum licensed power or CF, or the current plantvessel dome pressure. This report supports operation of NMP2 at current licensed thermal power(CLTP) of 3,988 MWt with CF as low as 85% RCF following implementation of the extendedpower uprate (EPU) at NMP2. The terms CLTP and EPU are used interchangeably throughout this document, and refer to the same power level of 3,988 MWt. The MELLLA+ core operating domain expansion does not require major plant systems modifications. The core operating domain expansion involves changes to the operating power/core flow map, minor systemmodifications, procedure

changes, and changes to a small number of instrument setpoints.

Because there are no increases in the operating

pressure, power, steam flow rate, and feedwater (FW) flow rate, there are no significant effects on the plant systems outside of the nuclear steamsupply system (NSSS). There is a potential increase in the steam moisture content at certaintimes while operating in the MELLLA+ operating domain. The effects of the potential increasein moisture content on plant systems have been evaluated and determined to be acceptable.

TheMELLLA+ operating domain expansion does not cause additional requirements to be imposedon any of the safety, balance-of-plant (BOP), electrical, or auxiliary systems. No changes to thepower generation and electrical distribution systems are required as a result of the MELLLA+operating domain expansion. Evaluations of the reactor, engineered safety features (ESFs), power conversion, emergency power, support systems, environmental issues, and design basis accidents (DBAs) wereix NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)performed. The following conclusions summarize the results of the evaluations presented in thisreport.* All safety aspects of the plant that are affected by MELLLA+ operating domainexpansion were evaluated.

  • There is no change in the existing design basis and licensing basis acceptance criteria ofthe plant.* Evaluations were performed using NRC-approved or industry-accepted analytical methods." Where applicable, more recent industry codes and standards were used.* No major hardware modifications to safety-related equipment are required to supportMELLLA+ operating domain expansion.

" Systems and components affected by MELLLA+ were reviewed to ensure that there is nosignificant challenge to any safety system." Potentially affected commitments to the NRC were reviewed.

  • Planned changes not yet implemented have also been reviewed for the effects ofMELLLA+.This report summarizes the results of the SEs needed to justify a licensing amendment to allowthe MELLLA+ operating domain expansion to a minimum CF rate of 85% of RCF at 100%CLTP. These SEs demonstrate that the MELLLA+ operating domain expansion can beaccommodated:

" without a significant increase in the probability or consequences of an accidentpreviously evaluated;

  • without creating the possibility of a new or different kind of accident from any accidentpreviously evaluated; and" without exceeding any presently existing regulatory limits or acceptance criteriaapplicable to the plant that might cause a reduction in a margin of safety.Therefore, the requested MELLLA+ operating domain expansion does not involve a significant hazards consideration.

x NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)ACRONYMSTerm Definition 1 RPT One Recirculation Pump Trip2RPT Two Recirculation Pump TripABSP Automated Backup Stability Protection AC Alternating CurrentADS Automatic Depressurization SystemAL Analytical LimitALARA As Low As Reasonably Achievable ANS American Nuclear SocietyANSI American National Standards Institute AOO Anticipated Operational Occurrence AOP Abnormal Operating Procedure AOT Allowable Outage TimeAP Annulus Pressurization APRM Average Power Range MonitorARI Alternate Rod Insertion ARS Amplified Response SpectraART Adjusted Reference Temperature ARTS APRM / RBM / Technical Specifications ASME American Society of Mechanical Engineers AST Alternate Source Termatom % Percentage of AtomsATWS Anticipated Transient Without ScramAV Allowable ValueBOC Beginning of CycleBOP Balance-of-Plant BPV Boiler and Pressure VesselBSP Backup Stability Protection BSW Biological Shield WallBTU/Ibm BTU per Pounds MassBWR Boiling Water ReactorBWRVIP Boiling Water Reactor Vessel and Internals ProjectCDA Confirmation Density Algorithm CDF Core Damage Frequency xi NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Term Definition cfmn Cubic Feet per MinuteCENG Constellation Energy Nuclear GroupCF Core FlowCFR Code of Federal Regulations CLTP Current Licensed Thermal PowerCO Condensation Oscillation COLR Core Operating Limits ReportCPR Critical Power RatioACPR Change in Critical Power RatioCRD Control Rod DriveCRDA Control Rod Drop AccidentCRGT Control Rod Guide TubeCS Core SprayCST Condensate Storage TankDBA Design Basis AccidentDC Direct CurrentDFFR Dynamic Forcing Functions ReportD/G Diesel Generator DIR Design Input RequestDOR Division of Responsibility DRF Design Record FileDSS-CD Detect and Suppress Solution-Confirmation DensityDSS-CD LTR DSS-CD Licensing Topical ReportDSS-CD TRACG LTR DSS-CD TRACG Licensing Topical ReportDTR Draft Task ReportDW DrywellECCS Emergency Core Cooling SystemsEDG Emergency Diesel Generator EFPY Effective Full Power YearEOC End of CycleEOOS Equipment Out-of-Service EOP Emergency Operating Procedure EPRI Electric Power Research Institute EPU Extended Power UprateEQ Environmental Qualification xii NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Term Definition ESF Engineered Safety FeatureOF Degrees Fahrenheit FAC Flow Accelerated Corrosion FCV Flow Control ValveFHA Fuel Handling AccidentFIV Flow-Induced Vibration FTR Final Task ReportFW Feedwater FWCF Feedwater Controller Failure (Maximum Demand)FWHOOS Feedwater Heater(s) Out-of-Service GEH GE-Hitachi Nuclear Energy Americas LLCGESTAR General Electric Standard Application for Reactor FuelGNF Global Nuclear Fuel -Americas LLCgpm Gallons Per MinuteGWd/ST Gigawatt Days per Short TonHCTL Heat Capacity Temperature LimitHELB High Energy Line BreakHFCL High Flow Control LineHPCI High Pressure Coolant Injection HPCS High Pressure Core SprayHVAC Heating, Ventilation, and Air Conditioning IASCC Irradiated Assisted Stress Corrosion CrackingICF Increased Core FlowID Internal DiameterIGSCC Intergranular Stress Corrosion CrackingILBA Instrument Line Break AccidentIPE Individual Plant Examination IPEEE Individual Plant Examination of External EventsIRM Intermediate Range MonitorISI In-Service Inspection JPSL Jet Pump Sensing LineLAR License Amendment RequestLCO Limiting Condition for Operation LCS Leakage Control SystemLERF Large Early Release Frequency xiii NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Term Definition LFWH Loss of Feedwater HeatingLHGR Linear Heat Generation RateLHGRFACf Linear Heat Generation Rate Flow FactorLOCA Loss-of-Coolant AccidentLOFW Loss of Feedwater LOOP Loss of Off-Site PowerLPCI Low Pressure Coolant Injection LPCS Low Pressure Core SprayLPRM Local Power Range MonitorLRNBP Generator Load Rejection Without BypassLTR Licensing Topical ReportMAPLHGR Maximum Average Planar Linear Heat Generation RateMCO Moisture Carryover MCPR Minimum Critical Power RatioMCPRr Flow-Dependent Minimum Critical Power RatioMCPR, Power-Dependent Minimum Critical Power RatioMCR Main Control RoomMELB Moderate Energy Line BreakMELC Moderate Energy Line CrackMELLLA Maximum Extended Load Line Limit AnalysisMELLLA+ Maximum Extended Load Line Limit Analysis PlusMFLPD Maximum Fraction of Limiting Power DensityMIP MCPR Importance Parameter M+LTR MELLLA+ Licensing Topical Report NEDC-33006P-A M+SAR MELLLA+ Safety Analysis Report (Plant Specific Safety Analysis Report)M+LTR SER MELLLA+ Safety Evaluation ReportMlbm/hr Millions Of Pounds Mass per HourMOC Middle of CycleMOP Mechanical Overpower MOV Motor-Operated ValveMPC Maximum Permissible Concentration MS Main SteamMSIV Main Steam Isolation ValveMSIVC Main Steam Isolation Valve ClosureMSIVF Main Steam Isolation Valve Closure with Scram on High Fluxxiv NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Term Definition MSL Main Steam LineMSLBA Main Steam Line Break AccidentMWd/ST Megawatt Days per Short TonMWe Megawatt-Electric MWt Megawatt-Thermal NCL Natural Circulation LineNMP2 Nine Mile Point Unit 2NMPNS Nine Mile Point Nuclear Station, LLCNPSH Net Positive Suction HeadNRC Nuclear Regulatory Commission NSSS Nuclear Steam Supply SystemNTSP Nominal Trip SetpointOBE Operating Basis Earthquake OLMCPR Operating Limit Minimum Critical Power RatioOLTP Original Licensed Thermal PowerOOS Out-of-Service OPRM Oscillation Power Range MonitorPCT Peak Cladding Temperature PDI Performance Demonstration Initiative ppm Parts per MillionPRA Probabilistic Risk Assessment PRFO Pressure Regulator Failure -Openpsi Pounds per Square Inchpsia Pounds per Square Inch -Absolutepsid Pounds per Square Inch -Differential psig Pounds per Square Inch -GaugePWP Project Work PlanQA Quality Assurance QAP Quality Assurance ProgramRAI Request for Additional Information RBM Rod Block MonitorRCF Rated Core FlowRCIC Reactor Core Isolation CoolingRCPB Reactor Coolant Pressure BoundaryRE Responsible Engineerxv NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Term Definition RG Regulatory GuideRHR Residual Heat RemovalRIPD Reactor Internal Pressure Difference RIS Regulatory Issue SummaryRLA Reload Licensing Analysisrpm Revolutions per MinuteRPS Reactor Protection SystemRPT Recirculation Pump TripRPTOOS Recirculation Pump Trip Out-of-Service RPV Reactor Pressure VesselRRS Reactor Recirculation SystemRSLB Recirculation Suction Line BreakRWCU Reactor Water CleanupRWE Rod Withdrawal ErrorRWM Rod Worth Minimizer SAD Amplitude Discriminator SetpointSAR Safety Analysis ReportSBO Station BlackoutSC Safety Communication SDC Shutdown CoolingSE Safety Evaluation SER Safety Evaluation ReportSGTS Standby Gas Treatment SystemSLMCPR Safety Limit Minimum Critical Power RatioSLO Single Loop Operation SLS Standby Liquid Control SystemSOP Special Operating Procedure SPC Suppression Pool CoolingSPDS Safety Parameter Display SystemSRLR Supplemental Reload Licensing ReportSRM Source Range MonitorSRO Strong Rod OutSRP Standard Review PlanSRV Safety Relief ValveSRVDL Safety Relief Valve Discharge Linexvi NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Term Definition SRVOOS Safety Relief Valve -Out-of-Service SSE Safe Shutdown Earthquake STP Simulated Thermal PowerTAF Top of Active FuelTBVOOS Turbine Bypass Out-of-Service TFW Feedwater Temperature TIP Traversing Incore ProbeTLO Two Loop Operation T-M Thermal-Mechanical TOP Thermal Overpower TR Topical ReportTS Technical Specifications TSD Task Scoping DocumentTSTF Technical Specification Task ForceTSV Turbine Stop ValveTTNBP Turbine Trip Without BypassTTWBP Turbine Trip With BypassUHS Ultimate Heat SinkUSAR Updated Safety Analysis ReportUSE Upper Shelf EnergyV&V Verification and Validation VPF Vane Passing Frequency wt.% Percent by Weightxvii NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)

1.0 INTRODUCTION

This report summarizes the results of all significant SEs performed that justify the expansion ofthe operating boundary to NMP2 operation at a CLTP of 3,988 MWt and with CF as low as 85%of RCF. The terms CLTP and EPU are used interchangeably throughout this document, andrefer to the same power level of 3,988 MWt. The changes expand the operating domain in theregion of operation with less than RCF, but do not increase the licensed power level or themaximum CF. The expanded operating domain is identified as MELLLA+.The scope of evaluations required to support the expansion of the CF operating domain to theMELLLA+ boundary is contained in the LTR NEDC-33006P-A, "Maximum Extended LoadLine Limit Analysis Plus," referred to as the M+LTR (Reference 1). This report provides asystematic disposition of the M+LTR subjects applied to NMP2, including performance of plant-specific assessments and confirmation of the applicability of generic assessments to support aMELLLA+ CF operating domain expansion. The MELLLA+ core operating domain expansion does not require major plant hardwaremodifications. In accordance with Limitation and Condition 12.2 of the NRC Safety Evaluation Report (SER) for MELLLA+ (Reference 1), referred to as the M+LTR SER, NMP2 willimplement the Detect and Suppress Solution-Confirmation Density (DSS-CD)

solution, withlimitations and conditions as identified in the DSS-CD LTR SER (Reference 2), consistent withthe M+LTR. DSS-CD requires a revision to the existing stability solution software.

Theoperating domain expansion involves changes to the operating power/core flow map and changesto a small number of instrument setpoints. Because there are no increases in the operating

pressure, power, steam flow rate, and FW flow rate, there are no significant effects on the planthardware outside of the NSSS. There is a potential increase in the steam moisture content atcertain times while operating in the MELLLA+ operating domain. The effects of the potential increase in moisture content on plant hardware have been evaluated and determined to beacceptable.

The MELLLA+ operating domain expansion does not cause additional requirements to be imposed on any of the safety, BOP, electrical, or auxiliary systems. No changes to thepower generation and electrical distribution systems are required due to the introduction ofMELLLA+.This report also addresses applicable limitations and conditions as described in the M+LTR SERand the NRC SER for the GE-Hitachi Nuclear Energy Americas LLC (GEH) LTRNEDC-33173P-A, "Applicability of GE Methods to Expanded Operating Domains," referred toas the Methods LTR SER (Reference 3).The disposition of each limitation and condition is discussed along with the relevant section ofthis report. A complete listing of the required M+LTR SER, Methods LTR SER, and DSS-CDLTR SER limitations and conditions and the sections of this report which address them ispresented in Appendices A, B, and C, respectively. 1-1 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)1.1 REPORT APPROACHThe evaluations provided in this report demonstrate that the MELLLA+ operating domainexpansion can be accomplished within the applicable safety design criteria. Many of the SEs andequipment assessments previously performed for the NMP2 EPU are unaffected because theMELLLA+ operating domain expansion effects are limited to the NSSS system.This NMP2 MELLLA+ safety analysis report (M+SAR) follows the same structure and contentas the M+LTR (Reference 1). Two dispositions of the evaluation topics are used to characterize the MELLLA+ evaluation scope. Topics are dispositioned as either "Generic" or"Plant-Specific" as described in Sections

1. 1.1 and 1.1.2, respectively.

1.1.1 Generic Assessments Generic assessments are those SEs that can be dispositioned by:* Providing or referencing a bounding analysis for the limiting conditions; " Demonstrating that there is a negligible effect due to MELLLA+;" Identifying the portions of the plant that are unaffected by the MELLLA+ power/flow map operating domain expansion; or* Demonstrating that the sensitivity to MELLLA+ is small enough that the required plantcycle-specific reload analysis process is sufficient and appropriate for establishing theMELLLA+ licensing basis in accordance with M+LTR SER Limitation andCondition 12.3.c and as defined in General Electric Standard Application for ReactorFuel (GESTAR) (Reference 4).As per M+LTR SER Limitation and Condition 12.4, the plant-specific MELLLA+application shall provide the plant-specific thermal limits assessment and transient analysis results. Considering the timing requirements to support the reload, the fuel andcycle-dependent analyses including the plant-specific thermal limits assessment may besubmitted by supplementing the initial M+SAR. Additionally, the Supplemental ReloadLicensing Report (SRLR) for the initial MELLLA+ implementation cycle shall besubmitted for NRC staff confirmation. Some of the SEs affected by MELLLA+ are fuel operating cycle (reload) dependent. Reload dependent evaluations require that the reload fuel design, core loading pattern,and operational plan be established so that analyses can be performed to establish coreoperating limits. The reload analysis demonstrates that the core design for MELLLA+meets the applicable NRC evaluation criteria and limits documented in Reference 4.1-2 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)]] No plant can enter the MELLLA+ domain unless the appropriate reload core analysis is performed and all criteria and limits documented in Reference 4are satisfied. Otherwise, the plant would be in an unanalyzed condition. Based oncurrent requirements, the reload analysis results are documented in the SRLR, and theapplicable core operating limits are documented in the plant-specific Core Operating Limits Report (COLR).NMP2 will supplement this M+SAR with the fuel and cycle dependent analysis including the plant-specific thermal limits assessment. Additionally, NMP2 will submit the SRLRfor the initial MELLLA+ implementation cycle for NRC staff confirmation. As required by M+LTR SER Limitation and Condition 12.5.a, Nine Mile Point NuclearStation, LLC (NMPNS) will modify NMP2 Technical Specification (TS) 3.4.1 to includea requirement that prohibits intentional single loop operation (SLO) while in theMELLLA+ operating domain, as defined in the COLR. This information is presented inthe NMPNS MELLLA+ license amendment request (LAR) for NMP2.As required by M+LTR SER Limitation and Condition 12.3.b, the applicability of thegeneric assessments to NMP2 is identified and confirmed in the applicable sections. Inthe event that the generic assessment presented in the M+LTR is not applicable to NMP2,a plant-specific evaluation per Section 1. 1.2 is completed to demonstrate the acceptability of the MELLLA+ operating domain expansion. 1.1.2 Plant-Specific Evaluation A NMP2-specific evaluation is provided for SEs not categorized as Generic. Where applicable, the assessment methodology in References 1, 4, 5, 6, or 7 is referenced. As required by M+LTRSER Limitation and Condition 12.3.a, the plant-specific evaluations performed and reported inthis document use plant-specific values to model the actual plant systems, transient

response, andcurrent operating conditions.

1.1.3 Computer Codes and MethodsNRC-approved or industry-accepted computer codes and calculational techniques are used in theevaluations for the MELLLA+ operating domain. The primary computer codes used for NMP2evaluations are listed in Table 1-1. The application of these codes complies with the limitations, restrictions, and conditions specified in the approving NRC SER. Exceptions to the use of thecode or special conditions of the applicable SER are included as notes to Table 1-1.The Methods LTR NEDC-33173P-A (Reference

3) documents all analyses supporting theconclusions in this section that the application ranges of GEH codes and methods are adequate inthe MELLLA+ operating domain. In accordance with the M+LTR SER Limitation andCondition
12. 1, the range of mass fluxes and power/flow ratios in the GEXL database covers theintended MELLLA+ operating domain. The database includes low flow, high qualities, and voidfractions.

There are no restrictions on the application of the GEXL-PLUS correlation in theMELLLA+ operating domain.1-3 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)As required by M+LTR SER Limitation and Condition 12.23.2, the NMP2-specific ODYN andTRACG calculations are provided to the NRC as required. As discussed in Section 1.0, the specific limitations and conditions associated with the M+LTR,Methods LTR, DSS-CD LTR, and DSS-CD TRACG LTR are discussed along with the relevantsection of this report. A complete listing of the required M+LTR SER, Methods LTR SER, andDSS-CD LTR SER limitations and conditions and the sections of this report which address themis presented in Appendices A, B, and C, respectively. 1.1.4 Scope of Evaluations Sections 2.0 through 11.0 provide evaluations of the MELLLA+ operating domain expansion onthe respective topics. The scope of the evaluations is summarized in the following sections. Section 2.0, Reactor Core and Fuel Performance: Core and fuel performance parameters areconfirmed for each fuel cycle, and will be evaluated and documented in the SRLR and COLR foreach fuel cycle that implements the MELLLA+ operating domain.Section 3.0, Reactor Coolant and Connected Systems: Evaluations of the NSSS components and systems are performed in the MELLLA+ operating domain. Because the reactor operating pressure and the CF are not increased by MELLLA+, the effects on the Reactor Coolant andconnected systems are minor. These evaluations confirm the acceptability of the MELLLA+changes to process variables in the NSSS.Section 4.0, Engineered Safety Features: The effects of MELLLA+ operating domainexpansion on the containment, emergency core cooling systems (ECCS), standby gas treatment system (SGTS), and other ESFs are evaluated. The operating pressure for ESF equipment is notincreased because operating pressure and safety relief valve (SRV) setpoints are unchanged as aresult of MELLLA+.Section 5.0, Instrumentation and Control: The instrumentation and control systems andanalytical limits (ALs) for setpoints are evaluated to establish the effects of MELLLA+ operating domain expansion on process parameters. The scope of MELLLA+ effects on the controls andsetpoints is limited because the MELLLA+ parameter variations are limited to the core.Section 6.0, Electrical Power and Auxiliary Systems: Because the power level is not changedby MELLLA+, the electrical power and distribution systems are not affected. The auxillary systems have been previously evaluated to ensure they are capable of supporting safe plantoperation at CLTP, which is unchanged by MELLLA+ operating domain expansion. Section 7.0, Power Conversion Systems: Because the pressure, steam flow, and FW flow donot change as a result of MELLLA+ operating domain expansion, the power conversion systemsare not affected by MELLLA+.Section 8.0, Radwaste Systems and Radiation Sources: The liquid and gaseous wastemanagement systems are not affected by the MELLLA+ operating domain changes. However,slightly higher loading of the condensate demineralizers is possible if the moisture carryover (MCO) in the reactor steam increases. The radiological consequences are evaluated to show thatapplicable regulations are met.1-4 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Section 9.0, Reactor Safety Performance Evaluations: The USAR anticipated operational occurrences (AOOs), DBAs, and special events are reviewed as part of the MELLLA+evaluation. Section 10.0, Other Evaluations: High energy line break (HELB) and environmental qualification (EQ) evaluations for the MELLLA+ domain are confirmed to demonstrate theoperability of plant equipment at MELLLA+ conditions. The effects on the individual plantexamination (IPE) are evaluated to demonstrate there is no significant change to the NMP2vulnerability to severe accidents. Section 11.0, Licensing Evaluations: This section includes the effect on TS. TheEnvironmental Assessment and the No Significant Hazards Consideration are provided as a partof the accompanying LAR.1.1.5 Product Line Applicability The M+LTR describes processes, evaluations, and dispositions applicable to GE boiling waterreactor (BWR) product lines BWR/3, BWR/4, BWR/5, and BWRI6. As such, the M+LTRprocess is applicable to NMP2, a BWR/5.1.1.6 Report Generation and Review ProcessThis M+SAR represents several years of project planning activities, engineering

analysis, technical verification, and technical review. The final stages of the M+SAR preparation includeM+SAR integration, additional review, on-site review committee review, and submittal to NRC.The NMP2 MELLLA+ project relied on the generic M+LTR (Reference
1) submitted to andapproved by the NRC (Reference 1).The project began with the respective GEH and NMPNS Project Managers creating a ProjectWork Plan (PWP). This PWP, developed in accordance with GEH engineering procedures, wasused to define the plant-specific work scope, inputs and outputs required for project activities.

Adivision of responsibility (DOR) between NMPNS and GEH was used to further develop thework scope and assign responsible engineers (REs) from each organization. A task scopingdocument (TSD) applicable for each GEH task was created,

reviewed, and approved by NMPNSprior to any technical work being performed.

Each GEH task RE submitted a design inputrequest (DIR) to the NMPNS task RE interface to define the correct plant information for use inthe GEH task analysis and evaluation. Additional DIRs were submitted as the project continued. A plant-specific M+SAR "shell" was created that contains the appropriate depth of information expected in the final M+SAR.All pertinent information is captured in an individual task design record file (DRF) maintained by the GEH RE with oversight by the respective engineering manager. Each DRF contains thequality assurance records applicable to the task, which includes evidence of design verification. A draft task report (DTR) was created for every GEH task. The DTR includes a description ofthe analysis performed, inputs, methods applied, results obtained and includes input to theapplicable M+SAR section(s). The DTR with M+SAR input was verified, in accordance withthe GEH quality assurance program (QAP), by a GEH technical verifier and a GEH Regulatory 1-5 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Affairs verifier, with oversight by the responsible GEH technical manager and GEH ProjectManager. The DTR with M+SAR input was transmitted by the GEH Project Manager toNMPNS and reviewed by the NMPNS RE and other NMPNS engineers, as appropriate. Subsequent comments were resolved between the GEH and the NMPNS REs and a final taskreport (FTR) with M+SAR input was developed. The FTR with M+SAR input was againverified (whether or not there were changes to the document), in accordance with the GEH QAP,by a GEH technical verifier and a GEH Regulatory Affairs verifier, with oversight by theresponsible GEH technical manager and GEH Project Manager. The GEH Project Managertransmitted the FTR with M+SAR input to the NMPNS Project Manager.For the NMP2 MELLLA+ project, NMPNS personnel:

1. Conducted multidisciplinary technical reviews of GEH evaluation reports (DTRswith M+SAR input and FTRs with M+SAR input) to ensure:i. Appropriate use of design inputs;ii. Consistency with the M+LTR; andiii. Design basis and licensing basis requirements were addressed.
2. Provided technical review results, in the form of detailed
comments, to GEHperformers;
3. Participated in discussions with GEH REs to address and resolve comments; and4. Controlled the application of the NMPNS off-site services process to GEH.The Regulatory Affairs RE integrated the individual M+SAR sections creating a Draft M+SARthat was verified, in accordance with the GEH QAP, by another GEH Regulatory Affairsengineer, with oversight by the GEH Regulatory Affairs Services Licensing Manager and theGEH Project Manager.

The GEH Project Manager transmitted the verified Draft M+SAR toNMPNS where it received another complete review by NMPNS's technical personnel, projectstaff, and Licensing staff.NMPNS personnel generated questions and comments, which were responded to by GEH'stechnical and Regulatory Affairs personnel. The M+SAR was then presented to the NMPNS'son-site review committee. After resolution of any final comments, the Final M+SAR wassubmitted to the NRC.A technical assessment of GEH's work was performed during reviews conducted at GEH officesin Wilmington, NC during January 2011. The scope of these assessments included workperformed by GEH and Global Nuclear Fuel -Americas LLC (GNF) in support of the NMP2MELLLA+ project. Participating in those activities were representatives of NMP2mechanical/structural,

nuclear, and reactor engineering disciplines, and project engineering.

TheNMP2 team reviewed design inputs, analysis methodologies, and results in the GEH DRFs. Thereviews included discussion with GEH technical task performers to obtain a thoroughunderstanding of GEH analysis methods.1.1.7 Report Generation and Review ProcessAs noted in Section 1.1.6 above, a DOR between NMPNS and GEH was used to further developthe work scope and assign REs from each organization. Tasks assigned to NMPNS REs were1-6 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)performed under the NMPNS 10 Code of Federal Regulations (CFR) 50, Appendix B QAP,where applicable. The NMPNS assigned tasks were performed internally by NMPNS engineers or contracted out to engineering consulting firms on the NMPNS approved supplier list. Whereapplicable, the contractors applied a 10 CFR 50 Appendix B QAP.NMPNS internal tasks were prepared,

reviewed, and approved in accordance with applicable procedures.

For contracted tasks, a TSD applicable for each task was created,

reviewed, and approved byNMPNS prior to any technical work being performed.

This work scope formed the basis for theMELLLA+ task. The design inputs were then collected,

reviewed, and forwarded to theengineering consultant, in accordance with applicable procedures.

FTRs, and other engineering

products, when issued, are processed through the NMPNSengineering change process as a final verification of acceptability and retained as a quality recordin the NMPNS nuclear records management system.1.2 OPERATING CONDITIONS AND CONSTRAINTS 1.2.1 Power/Flow MapThe NMP2 power/flow map including the MELLLA+ operating domain expansion is shown inFigure 1-1. [[All lines on the power/flow map in Figure 1-1, other than those associated with the MELLLA+operating domain expansion, are unchanged by MELLLA+.As required by M+LTR SER Limitation and Condition 12.5.c, NMP2 will include thepower/flow map in the COLR after the MELLLA+ operating domain expansion is approved.

The MELLLA+ domain extends from 55% RCF at 77.6% EPU to 85% RCF at 100% EPU.Normal core performance characteristics for plant power/flow maneuvers at near full power canbe accomplished above 55% CF. Due to stability considerations at high power and low CF, theMELLLA+ domain was not extended below 55% RCF. The reactor operating conditions following an unplanned event could stabilize at a power/flow point outside the allowed operating domain. If this occurs the operator must reduce power or increase flow in accordance with plantprocedures to place the plant back into the allowed operating domain.The steady-state core thermal power to CF ratio for operation in the MELLLA+ domain is listed inTable 1-3. Each point listed is in compliance with the Methods LTR SER Limitation andCondition 9.3 of 50 MWt/Mlbmihr with the exception of the point of low flow/ high power, point'M' (55% RCF / 77.6% EPU), on Figure 1-1. The point on the power/flow map is only marginally above the limit and is not used for extended periods of operation. Because the limitation is notintended to place operational restrictions on the plant (Reference 3.c), the NMP2 MELLLA+power/flow map shall remain as shown in Figure 1-1, without any additional restrictions. 1-7 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)As NMP2 exceeds the power-to-flow ratio of 50 MWt/Mlbm/hr at 55% RCF, an assessment of thelimitation with respect to the conservatism of the power distribution uncertainties is performed. Theresults of this assessment are provided in Section 2.2.5.1.2.2 Reactor Heat BalanceThe reactor heat balance is affected. Operation in the MELLLA+ domain, with lower CF, results ina decrease in recirculation pump heat and core inlet enthalpy. 1.2.3 Core and Reactor Conditions As mentioned previously, the MELLLA+ operating domain expansion results in changes to thecore and reactor.Table 1-2 compares Maximum Extended Load Line Limit Analysis (MELLLA) and MELLLA+thermal-hydraulic operating conditions for NMP2. The differences shown in Table 1-2 aretypical of other BWR plants analyzed for MELLLA+ operating domain expansion, and the coreoperating conditions listed in Table 1-3 represent the maximum allowed power-to-flow ratiostatepoints within the boundaries of the MELLLA+ operating domain. [[]]The decay heat is principally a function of the reactor power level and the irradiation time. TheMELLLA+ operating domain expansion does not alter either of these two parameters, andtherefore, there is no first order effect on decay heat. Enrichment,

exposure, void fraction, powerhistory, cycle length, and refueling batch fraction have a second order effect on decay heat.1]1.2.4 Operational Enhancements The following table provides the performance improvement and/or equipment out-of-service (EOOS) features applicable to NMP2 and whether they are allowed in the MELLLA+ operating domain. The table also dispositions other operational enhancements that were discussed in theM+LTR (Reference 1).Operational Enhancements MELLLA+ NMP2 M+SARIncreased Core Flow (ICF) Allowed IncludedSingle Loop Operation Not Allowed Not IncludedSafety Relief Valve -Out-of-Service (SRVOOS)

(2 valves) Allowed IncludedAverage Power Range Monitor (APRM) / Rod Block Allowed IncludedMonitor (RBM) / Technical Specifications (ARTS)Recirculation Pump Trip Out-of- Service (RPTOOS) Allowed Included1-8 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Turbine Bypass Out-of-Service (TBVOOS) Allowed IncludedMain Steam Isolation Valve (MSIV) Out-of-Service (OOS) Allowed IncludedTwo Automatic Depressurization System (ADS) Valves Out- Allowed Includedof-Service 20'F FW Operational Temperature Band Allowed Included24 Month Cycle Allowed Included60-Year Plant Life Allowed IncludedThe evaluations performed in support of MELLLA+ operating domain expansion consider eachof the operational enhancements listed as "Allowed." Because the operational enhancements areconsidered as a part of the design inputs for evaluations performed in support of MELLLA+operating domain expansion, these operational enhancements are evaluated across the scope ofthis M+SAR and are therefore not dispositioned in a specific section.The existing NMP2 License Condition 7 restricts operation with FW heating to within20 degrees of the design FW temperature which satisfies M+LTR SER Limitation andCondition 12.5.b.SLO in the MELLLA+ domain is not proposed. The present licensing basis for SLO remainsapplicable per plant TS.As required by M+LTR SER Limitation and Condition 12.5.a, NMPNS will modify NMP2TS 3.4.1 to include a requirement that prohibits intentional SLO operation while in theMELLLA+ operating domain as defined in the COLR. This information is presented in theNMPNS MELLLA+ LAR for NMP2.1.3 SUMMARY AND CONCLUSIONS This M+SAR documents the results of analyses necessary to expand the operating domain of theNMP2 plant to include the MELLLA+ domain. This document conforms to the scope, contentand structure described in the M+LTR, which the NRC has determined "is acceptable forreferencing in licensing applications for GE-designated boiling water reactors to the extentspecified and under the limitations and conditions delineated in the TR [topical report] and in theenclosed final SE [safety evaluation]." 1-9 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Table 1-1 Computer Codes Used in the M+SAR Evaluations Task Computer Version or NRC CommentsCode* Revision ApprovedReactor Heat Balance ISCOR 09 Y(l) NEDE-2401 IP Rev. 0 SERReactor Core and Fuel TGBLA 06 Y(2) NEDE-30130P-A Performance PANACEA 11 Y(2) NEDE-30130P-A ISCOR 09 Y(l) NEDE-240I P Rev. 0 SERPRIME 03 Y(17) NEDC-33256P-A Revision I,NEDC-33257P-A Revision 1,NEDC-33258P-A Revision 1Thermal Hydraulic Stability ODYSY 05 Y NEDC-33213P-A TRACG 04 Y(14) NEDE-33147P-A Rev. 4ISCOR 09 Y(l) NEDE-2401 IP Rev. 0 SERPANACEA II Y(3) NEDE-30130P-A Reactor Internal Pressure LAMB 07 (4) NEDE-20566P-A, September 1986Differences TRACG 02 Y(5) NEDE-32176P, Rev. 0, February 1993NEDE-32177P, Rev. 1, June 1993NRC TAC No. M90270, Sept. 1994ISCOR 09 Y(l) NEDE-2401 1P Rev. 0 SERReactor Recirculation BILBO 04V (8) NEDE-23504, Feb. 1977System (RRS)Reactor Pressure Vessel TGBLA 06 Y(2) NEDE-30130P-A (RPV) Fluence DORTG 01 Y(l 1, 12) CCC-543Containment System M3CPT 05 Y NEDO-10320, April 1971 (Reference 8)Response and NUREG-0808 (Reference 9)NEDE-20566P-A, September 1986LAMB 08 (4) (Reference 10)Break Flow Mass/Energy TRACG 04 N(I 5) NEDE-32176P Rev. 4, January 2008Release Rates NEDE-32177P Rev. 3, August 2007NEDO-33083-A Rev. 1, September 2010Annulus Pressurization (AP) ISCOR 09 Y(l) NEDE-2401 IP Rev. 0 SERLoads GOTHIC 7.2b N(16)AP Loads -RPV and SAP4G 07 N(8) NEDO-10909, Rev. 7, December 1979Internals' Structural SPECA 05 N(8) NEDE-25181, August 1996Analysis PDA 02 N(8) NEDE-10813A, February 1976ECCS-Loss-of-Coolant LAMB 08 Y NEDE-20566P-A Accident (LOCA) PRIME 01 Y(17) NEDC-33256P-A, Rev. 101 Y NEDC-33257P-A, Rev. 101 Y NEDC-33258P-A, Rev. ISAFER 04 Y (9) (10)ISCOR 09 Y(l) NEDE-2401 IP Rev. 0 SERTASC 03 Y NEDC-32084P-A 1-10 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Task Computer Version or NRC CommentsCode* Revision ApprovedTransient Analysis PANACEA 11 Y NEDE-30130P-A (6)ODYN 09 Y NEDE-24154P-A (Reference Ii)NEDC-24154P-A, Vol. 4, Sup I(Reference 11)ISCOR 09 Y(1) NEDE-2401 IP Rev. 0 SERTASC 03 Y NEDC-32084P-A Rev. 2Anticipated Transient ODYN 09 Y NEDC-24154P-A, Vol. 4, Sup. IWithout Scram (ATWS) STEMP 04 (7)PANACEA 11 Y(6)TASC 03A Y NEDC-32084P-A Rev. 2ISCOR 09 Y(l) NEDE-2401 IP Rev. 0 SERTRACG 04 N(I 3) 1__The application of these codes to the MELLLA+ analyses complies with the limitations, restrictions, andconditions specified in the approving NRC SER where applicable for each code. The application of the codesalso complies with the SERs for the MELLLA+ programs. Notes for Table 1-1:(1) The ISCOR code is not approved by name. However, in the SER supporting approval of NEDE-2401 1PRevision 0 by the May 12, 1978 letter from D. G. Eisenhut (NRC) to R. Gridley (GE), the NRC finds themodels and methods acceptable for steady-state thermal-hydraulic

analysis, and mentions the use of a digitalcomputer code. The referenced digital computer code is ISCOR. The use of ISCOR to provide corethermal-hydraulic information in reactor internal pressure differences (RIPDs),

transient, ATWS, stability, and LOCA applications is consistent with the approved models and methods.(2) The use of TGBLA Version 06 and PANACEA Version 11 was initiated following approval of Amendment 26 of GESTAR II by letter from S. A. Richards (NRC) to G. A. Watford (GE)

Subject:

"Amendment 26 toGE Licensing Topical Report NEDE-2401 1P-A, GESTAR II Implementing Improved GE Steady-State Methods (TAC NO. MA648 1)," November 10, 1999.(3) The use of PANACEA Version 11 was initiated following approval of Amendment 26 of GESTAR II byletter from S. A. Richards (NRC) to G. A. Watford (GE)

Subject:

"Amendment 26 to GE Licensing TopicalReport NEDE-24011P-A, GESTAR II Implementing Improved GE Steady-State Methods," (TACNO. MA6481), November 10, 1999.(4) The LAMB code is approved for use in ECCS-LOCA applications (NEDE-20566P-A), but no approving SERexists for the use of LAMB for the evaluation of RIPDs or containment system response. The use of LAMBfor these applications is consistent with the model description of NEDE-20566P-A. (5) NRC has reviewed and accepted the TRACG application for the flow-induced loads on the core shroud asstated in NRC SER TAC No. M90270.(6) The physics code PANACEA (PANAC) provides inputs to the transient code ODYN. The use of PANACEAVersion 11 in this application was initiated following approval of Amendment 26 of GESTAR II by letterfrom S. A. Richards (NRC) to G. A. Watford (GE)

Subject:

"Amendment 26 to GE Licensing Topical Report1-11 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)NEDE-2401 I P-A, GESTAR II Implementing Improved GE Steady-State Methods," (TAC NO. MA648 1),November 10, 1999.(7) The STEMP code uses fundamental mass and energy conservation laws to calculate the suppression poolheatup. The use of STEMP was noted in NEDE-24222, "Assessment of BWR Mitigation of ATWS,Volume I & II (NUREG-0460 Alternate No. 3) December 1, 1979." The code has been used in ATWSapplications since that time. There is no formal NRC review and approval of STEMP or the ATWS TR.(8) Not a safety analysis code that requires NRC approval. The code application is reviewed and approved byGEH for "Level-2" application and is part of GEH's standard design process. The application of this codehas been used in other MELLLA+ and power uprate submittals. (9) "SAFER Model for Evaluation of Loss-of-Coolant Accidents for Jet Pump and Non-Jet Pump Plants,"NEDE-30996P-A, General Electric

Company, October 1987.(10) Letter, Richard E. Kingston (GEH) to NRC, "Transmittal of Revision 1 of NEDC-32950, Compilation ofImprovements to GENE's SAFER ECCS-LOCA Evaluation Model," MFN 07-406, July 31, 2007.(11) CCC-543, "TORT-DORT Two- and Three-Dimensional Discrete Ordinates Transport Version 2.8.14,"Radiation Shielding Information Center (RSIC), January 1994.(12) The use of DORTG was approved by the NRC through the letter from H. N. Berkow (NRC) to G. B.Stramback (GE), "Final Safety Evaluation Regarding Removal of Methodology Limitations forNEDC-32983P-A, General Electric Methodology for Reactor Pressure Vessel Fast Neutron Flux Evaluations (TAC No. MC3788),"

November 17, 2005.(13) The TRACG04 code is not approved by the NRC for long-term ATWS calculations including ATWS withdepressurization and ATWS with core instability.

However, TRACG04 is used as a best-estimate code, whileODYN remains as the licensing basis code for ATWS consistent with the NRC SE for NEDC-33006P.

Theuse of TRACG04 for the best-estimate TRACG ATWS analysis is also consistent with the NRC SE forNEDC-33006P. TRACG04 is approved by the NRC for application to ATWS overpressure transients inNEDE-32906P Supplement 3-A, "Migration to TRACGO4 / PANAC 1I from TRACG02 / PANAC1O forTRACG AOO and ATWS Overpressure Transients," April 2010.(14) The TRACG04 application for DSS-CD is documented in NEDE-33147P-A Revision 4 (Reference 12).(15) The TRACG break flow model and qualification basis is described in NEDE-32176P and NEDE-32177P. The application of TRACG04 for the calculation of break flow mass/energy release rates has been approvedfor ESBWR LOCA application in NEDO-33083-A. (16) GOTHIC quality assurance (QA) Version 7.2b has been applied in several NRC approved primarycontainment/subcompartment evaluation analyses including the NMP2 EPU peak pressure evaluations toaddress GEH Safety Communication (SC) 09-05 submitted on October 8, 2010 (Reference 13). Theassociated NRC SER for the NMP2 EPU LAR was issued on December 22, 2011 (Reference 14).(17) Application of PRIME models and data to downstream methods is approved by NEDO-33173 Supplement 4-A, "Implementation of PRIME Models and Data in Downstream Methods," Revision 1,November 2012 (Reference 3).1-12 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Table 1-2 Comparison of Thermal-Hydraulic Parameters MELLLA MELLLA+ MELLLA+Parameter 100% CLTP, 100% CLTP, 77.6% CLTP,99% Core Flow 85% Core Flow 55% Core FlowThermal Power (MWt) 3988 3988 3095Dome Pressure (psia) 1035 1035 1011Steam Flow Rate (Mlbm/hr) 17.636 17.633 13.115FW Flow Rate (Mlbm/hr) 17.604 17.601 13.083FW Temperature ('F) 440.5 440.5 411.4Core Flow (Mlbrn/hr) 107.4 92.2 59.7Core Inlet Enthalpy (BTU/Ibm) 528.7 525.2 511.4Core Pressure Drop (psi) 25.0 20.2 10.7Core Average Void Fraction 0.504 0.531 0.532Core Exit Void Fraction 0.723 0.755 0.766Table 1-3 Core Thermal Power to Core Flow RatiosPoint on the Core Thermal Core Flow Power-to-Flow Steady-State Operation Power/Flow Power RatioMap (MWt/%CLTP) (Mlbm/hr/%rated) (MWt/Mlbm/hr) Current Operating Domain E 3988 /100 108.5 /100 36.76100% Rated Core FlowCurrent Operating Domain D 3988 / 100 107.4/99 37.1399% Rated Core FlowMELLLA+Operating Domain N 3988 /100 92.2 / 85 43.2485% Rated Core FlowMELLLA+Operating Domain M 3095 / 77.6 59.7 / 55 51.8655% Rated Core Flow1-13 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Core Flow (Mlbm/hr) 0 10 20 30 40 50 60 7080 90 100 110 120 1301201101009080f"7060so3020100100% CLTP = 3988 MWt86.9% CLTP (Pre-EPU) 3467 MWt100% Core Flo1 = 108.5 Mlbrn/hr450040003500300025002000 Ei150010005000 10 20 30 40 50 60 70 80 90 100 110 120Core Flow (%)Figure 1-1 Power/Flow Operating Map for MELLLA+1-14 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)2.0 REACTOR CORE AND FUEL PERFORMANCE This section addresses the evaluations that are applicable to MELLLA+.Because NMP2 currently uses only GE14 fuel, the following limitations and conditions from theMethods LTR SER and M+LTR SER are not applicable to the NMP2 M+SAR:Methods LTR SER Limitations and Conditions: APPLICATION OF 10 WEIGHT PERCENT GD: Limitation and Condition 9.13MIXED CORE METHOD 1: Limitation and Condition 9.21MIXED CORE METHOD 2: Limitation and Condition 9.22M+LTR SER Limitations and Conditions: CONCURRENT CHANGES: Limitations and Conditions 12.3.d, 12.3.e, and 12.3.fAPPENDIX -A Request for Additional Information (RAI) 14-9: Limitation andCondition 12.23.6APPENDIX -A RAI 14-10: Limitation and Condition 12.23.72.1 FUEL DESIGN AND OPERATION The effect of MELLLA+ on the fuel design and operation is described below. The topicsaddressed in this evaluation are:M+LTRTopic Disposition NMP2 ResultFuel Product Line Design [[Core DesignFuel Thermal Margin Monitoring Threshold ]]2.1.1 Fuel Product LineThe fuel design limits are established for all new fuel product line designs as a part of the fuelintroduction and reload analyses. The M+/-LTR establishes that there are no changes in fuelproduct line design as a consequence of MELLLA+. Because implementation of the MELLLA+operating domain does not necessitate a new fuel design, no additional fuel and core designevaluation is required. NMP2 currently operates with GEl4 fuel. The cycle in which MELLLA+ operating domainexpansion is implemented shall contain GEl4 fuel. [[]] no new fuel product line design is introduced, and there is no change to fueldesign limits required by the MELLLA+ introduction at NMP2. Therefore, the SRLR willconfirm that there are no new fuel products as a result of MELLLA+ and will validate theconclusion that no additional fuel and core design evaluation is required for NMP2.2-1 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)2.1.2 Core Design and Fuel Thermal Monitoring Threshold [[]] the maximum licensed power level and fuel design do not changeas a result of MELLLA+. [[ ]]there is no change to the average power density as a result of MELLLA+ operating domainexpansion. Because the maximum licensed power level and fuel design do not change as a resultof MELLLA+, there is no increase in the average bundle power. Because there is no change inaverage power density, there is no change required to the fuel thermal monitoring threshold. [[ ]] there are no changes to the NMP2fuel or fuel design limits as a result of MELLLA+. NMP2 continues to use GEl4 fuel. TheCLTP remains at 3,988 MWt. This validates the conclusion that there are no changes needed tothe fuel thermal monitoring threshold for NMP2.Furthermore, because the MELLLA+ operating domain allows higher bundle power versus flowconditions, [[ ]] the range of void fraction, axialand radial power shape, and rod positions in the core may change slightly. The change in powerdistribution in the core is achieved, while the individual fuel bundles remain within the allowable thermal limits as defined in the COLR.Also, [[ ]], and per Methods LTR SER Limitation andCondition 9.17, the range of void fraction, axial and radial power shape, and rod positions in thecore does change slightly as a result of MELLLA+ operating domain expansion. For NMP2, thepredicted bypass void fraction at the D-Level local power range monitor (LPRM) satisfied the[[ ]] design requirement. The cycle-specific SRLR will confirm that the void fraction is< 5% according to Methods LTR SER Limitation and Condition 9.17. The table below showsthat steady-state bypass voiding is demonstrated on the MELLLA+ upper boundary at 100%power.% of Rated Core % of Rated Hot Channel Void Fraction in Bypass Region atItemPower Core Flow Instrumentation D Level (ISCOR Node 21)1 100 99 1.6%2 100 85 3.0%As required by Methods LTR SER Limitation and Condition 9.24, the following core design andfuel monitoring parameters are plotted as indicated below in Table 2-1 and Figures 2-1 through2-6 for each cycle exposure statepoint. The parameters are compared to the experience basereported in Reference 3:Table 2-1 Peak Nodal Exposures Figure 2-1 Power of Peak Bundle versus Cycle ExposureFigure 2-2 Coolant Flow for Peak Bundle versus Cycle ExposureFigure 2-3 Exit Void Fraction for Peak Power Bundle versus Cycle Exposure2-2 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Figure 2-4 Maximum Channel Exit Void Fraction versus Cycle ExposureFigure 2-5 Core Average Exit Void Fraction versus Cycle ExposureFigure 2-6 Peak LHGR versus Cycle ExposureAs part of the information requested for M+LTR SER Limitation and Condition 12.24.2, the exitvoid fraction for peak power bundle versus cycle exposure is provided in Figure 2-3.Also, quarter core maps with mirror symmetry are plotted in Figure 2-7 through Figure 2-15showing bundle power, bundle operating linear heat generation rate (LHGR), and minimumcritical power ratio (MCPR) for beginning of cycle (BOC) (0.2 GWd/ST), middle of cycle(MOC) (10.0 GWd/ST), and end of cycle (EOC) (18.577 GWd/ST). The maximum fraction oflimiting power density (MFLPD) occurs at 15.0 GWd/ST (Figure 2-16) and the largest maximumfraction of limiting critical power ratio (MFLCPR) occurs at 1.5 GWd/ST (Figure 2-17) for thiscore design. In Figure 2-7 through Figure 2-9, the bundle power is dimensionless. To obtain thebundle power in MWt, multiply each number by the average power per bundle. Prior to EOC,the average power per bundle is 5.2199; this factor equals 3,988/764, where 3,988 MWt is theRTP and 764 is the total number of fuel bundles in the core. At EOC, the average power perbundle is 4.6648.Table 2-1 shows that NMP2's Peak Nodal Exposure are lower than the top four reference plants.Figures 2-1 through 2-4 and Figure 2-6 show NMP2 MELLLA+ operation is in the expectedrange as compared to the reference plants. Figure 2-5 shows that NMP2 is higher than all theother plants. This is because of NMP2 MELLLA+ operating conditions, which are at full EPUpower and 85% flow, while the available data for other plants are not at full EPU and/orMELLLA+ conditions. Figures 2-7 through 2-9 show the relative bundle power for BOC, MOC,and EOC, respectively. Figures 2-10 through 2-12 show the operating LHGR for BOC, MOC,and EOC, respectively. Figures 2-13 through 2-15 show the MCPR for BOC, MOC, and EOC,respectively. Figures 2-7 through 2-17 show general operational conditions for NMP2 in theMELLLA+ operating domain are well within expected parameters. 2.2 THERMAL LIMITS ASSESSMENT The effect of MELLLA+ on the MCPR safety and operating limits, maximum average planarlinear heat generation rate (MAPLHGR), and LHGR limits is described below. As required byLimitation and Condition 9.6 of the Methods LTR SER, the GE14 fuel bundle R-factors generated for this project are consistent with GNF standard design practices, which use an axialvoid profile shape with 60% average in-channel voids. This is consistent with lattice axial voidconditions expected for the hot channel operating state as shown in Figure 2-18. As required byMethods LTR SER Limitation and Condition 9.15, the nodal void reactivity biases applied inTRACG are applicable to the lattices representative of fuel loaded in the core.The topics addressed in this evaluation are:2-3 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Topic M+LTR Disposition NMP2 ResultSafety Limit MCPR Operating Limit MCPRMAPLHGR LimitLHGR Limit 2.2.1 Safety Limit Minimum Critical Power RatioEr]] the SLMCPR is calculated based on the actual coreloading pattern for each reload core. In the event that the cycle-specific SLMCPR is notbounded by the current NMP2 TS value, NMP2 must implement a license amendment to changethe TS.[[ ]] the SLMCPR analysis for NMP2reflects the actual plant core loading pattern and is performed for each reload core. The cycle-specific SLMCPR will be determined using the methods defined in Reference

4. As required byM+LTR SER Limitation and Condition 12.6, the SLMCPR will be calculated at the ratedstatepoint (100% CLTP / 100% CF), the upper right comer of the MELLLA+ upper boundary(100% CLTP / 85% CF), the lower left comer of the MELLLA+ upper boundary (77.6% CLTP /55% CF), and the CLTP at the ICF statepoint (100% CLTP / 105% CF) (i.e., Figure 1-1Statepoints E, N, M, and F, respectively).

See Section 1.2.1 for further information on thepower-to-flow statepoints. The currently approved off-rated CF uncertainty applied to the SLOoperation is used for the minimum CF Statepoint N and at 55.0% CF Statepoint M. Thecalculated values will be documented in the SRLR.As required by Methods LTR SER Limitation and Condition 9.5 and M+LTR SER Limitation and Condition 12.24.3, for MELLLA+ operation, a +0.02 adder will be added to thecycle-specific SLMCPR. The cycle-specific SLMCPR analysis will incorporate the +0.02 adderfor MELLLA+ operation. The calculated values will be documented in the SRLR. A TS changewill be requested if the current value is not bounding. 2.2.2 Operating Limit Minimum Critical Power Ratio]] the OLMCPR is calculated by adding the change inMCPR due to the limiting AOO event to the SLMCPR. [[]] The OLMCPR is determined on a cycle-specific basis from2-4 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)the results of the reload transient

analysis, as described in Reference
4. The cycle-specific analysisresults are documented in the SRLR and included in the COLR. The MELLLA+ operating conditions do not change the methods used to determine this limit.[[ ]] the OLMCPR for NMP2 iscalculated by adding the change in MCPR due to the limiting AOO event to the SLMCPR.]] if the Methods LTR SER and M+LTR SER penalties are ignored for NMP2. The OLMCPR for NMP2 is determined on a cycle-specific basis from theresults of the reload transient
analysis, as described in Reference
4. The NMP2 cycle-specific analysis results are documented in the SRLR and included in the COLR. The MELLLA+operating conditions do not change the methods used to determine this limit. A +0.01 adder willbe applied to the resulting OLMCPR as required by Limitation and Condition 9.19 of theMethods LTR SER. In the event that the cycle-specific reload analysis is based on TRACGrather than ODYN for AOO, no 0.01 adder to the OLMCPR is required.

[[2.2.3 Maximum Average Planar Linear Heat Generation Rate Limits[R ]] MAPLHGR limitsensure that the plant does not exceed regulatory limits established in 10 CFR 50.46. Section 4.3,Emergency Core Cooling System Performance, presents the evaluation to demonstrate that plantsmeet the regulatory limits in the MELLLA+ operating domain. 1Er ]] the NMP2 MAPLHGR limitsensure that NMP2 does not exceed regulatory limits established in 10 CFR 50.46. Section 4.3 ofthis M+SAR presents the evaluation to demonstrate that NMP2 meets the regulatory limits in theMELLLA+ operating domain. [[]] The MELLLA+ operating conditions do not change the methods used to determine this limit.2.2.4 Linear Heat Generation Rate LimitsEr LHGR limits ensure thatthe plant does not exceed fuel thermal-mechanical (T-M) design limits. The LHGR isdetermined by the fuel rod T-M design and is not affected by MELLLA+ operating domainexpansion. No changes to the fuel rod are required as a part of MELLLA+. [[2-5 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)]] the NMP2 LHGR limits ensurethat the plant does not exceed fuel T-M design limits. There are no changes to the NMP2 fuel orfuel design limits as a result of MELLLA+. NMP2 continues to use GEl4 fuel. [[]] The MELLLA+ operating conditions do not change the methods used to determine this limit.[[2.2.5 Power-to-Flow RatioMethods LTR SER Limitation and Condition 9.3 requires that plant-specific EPU and expandedoperating domain applications confirm that the core thermal power to CF ratio does not exceed50 MWt/Mlbm/hr at any statepoint in the allowed operating domain. For plants that exceed thepower-to-flow value of 50 MWt/Mlbmihr, the application will provide a power distribution assessment to establish that axial and nodal power distribution uncertainties determined vianeutronic methods have not increased. The core thermal power to CF ratio at steady-state and off-rated conditions along the MELLLA+boundary is reported in Table 2-2.2.3 REACTIVITY CHARACTERISTICS The effect of MELLLA+ on hot excess reactivity, strong rod out (SRO) shutdown margin, andSLS shutdown margin is described below. The topics addressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultHot Excess Reactivity Strong Rod Out Shutdown MarginSLS Shutdown Margin2.3.1 Hot Excess Reactivity operation in the MELLLA+ operating domain may change the hot excess reactivity during thecycle. This change in reactivity does not affect safety and is not expected to significantly affectthe ability to manage power distribution through the cycle and to achieve the target power level.]] The MELLLA+ operating conditions do notchange the methods used to evaluate hot excess reactivity. 2-6 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)]] NMP2 continues to operate on a 24-month cycle. TheMELLLA+ operating conditions do not change the NMP2 methods used to evaluate thatsufficient hot excess reactivity exists to match the 24 -month cycle conditions. 2.3.2 Strong Rod Out Shutdown Marginhigher core average void fraction results in higher plutonium production, increased hot reactivity later in the operational cycle, and decreased hot-to-cold reactivity differences. Smaller coldshutdown margins may result from cores designed for operation with the MELLLA+ operating domain expansion. This potential loss in margin is offset through core design to maintain currentdesign and TS cold shutdown margin requirements. All minimum SRO shutdown marginrequirements apply to cold most reactive conditions and are maintained without change forMELLLA+ implementation. In order to account for reactivity uncertainties, including the effectsof temperature and analysis

methods, margin well in excess of the TS limits is included in thedesign requirements.

[[The MELLLA+ operating conditions do not change the methods used to evaluate SRO shutdownmargin.I NMP2 current design and TS cold shutdown marginlimits are unchanged by MELLLA+. The MELLLA+ operating conditions do not change theNMP2 methods used to evaluate that SRO shutdown margin meets the current NMP2 design andTS cold shutdown limits.2.3.3 SLS Shutdown Margin]] higher core average void fraction results in higher plutonium production, increased hot reactivity later in the operational cycle, and decreased hot-to-cold reactivity differences. Smaller cold shutdown margins may result from cores designed for operation with the MELLLA+ operating domain expansion. This potential loss in margin is offset throughcore design to maintain current design and SLS TS requirements. All minimum SLS TSrequirements apply to most reactive SLS conditions and are maintained without change forMELLLA+ implementation. In order to account for reactivity uncertainties, including the effectsof temperature and analysis

methods, margin in excess of the TS limits is included in the design2-7 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION

-CLASS I (PUBLIC)requirements. [[]] The MELLLA+operating conditions do not change the methods used to evaluate the SLS shutdown margin.i NMP2 current design and SLS TS requirements for minimumnatural boron equivalent are unchanged by the SLS performance modification or MELLLA+.The MELLLA+ operating conditions do not change the NMP2 methods used to evaluate thatSLS shutdown margin meets the current NMP2 design and SLS TS requirements. The SLSperformance modifications are to increase the boron injection rate to support ATWS evaluations and do not affect the SLS shutdown margin evaluation.

2.4 STABILITY

The DSS-CD stability solution (Reference

2) has been shown to provide an early trip signal uponinstability inception prior to any significant oscillation amplitude growth and MCPR degradation for both core-wide and regional mode oscillations.

NMP2 will implement the DSS-CD solutionconsistent with the M+LTR. DSS-CD implementation includes any limitations and conditions inthe DSS-CD SER (Reference 2). In accordance with DSS-CD LTR SER Limitation andCondition 5.1 (Reference 2), because NMP2 is implementing DSS-CD using the NRC approvedGEH Option III platform, a plant-specific review is not required. There were no changesproposed in the bounding uncertainty or in the process to bound the uncertainty in the MCPR.Topic M+LTR Disposition NMP2 ResultDSS-CD Setpoints Armed RegionBackup Stability Protection (BSP) 2.4.1 DSS-CD Setpoints ]] As a part of DSS-CD implementation, the applicability checklist is incorporated into the reload evaluation process and is documented in the SRLR.DSS-CD implementation also includes incorporation of appropriate [[ ]] analysesto be performed if a specific reload analysis [[]] DSS-CD is incorporated per the requirements of the DSS-CDLTR. This implementation requires that a process for reviewing the DSS-CD setpoints for eachreload analysis is in place. [[2-8 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)]] no further review of MELLLA+ isnecessary to evaluate the adequacy of the DSS-CD setpoints. [[ ]] NMP2 will incorporate theDSS-CD solution consistent with the requirements of the DSS-CD LTR. Implementation ofDSS-CD in accordance with the DSS-CD LTR ensures that NMP2 incorporates the applicability checklist into the reload evaluation process and documents the results of the applicability checklist review in the SRLR. DSS-CD implementation per the DSS-CD LTR also ensures thatNMP2 incorporates appropriate [[ ]] analyses to be performed if a specific reloadanalysis [[The generic DSS-CD licensing basis applicable to NMP2 is documented in Section 4.7 ofReference

2. [[]] The step-by-step process summary for DSS-CD application of higher amplitude discriminator setpoint (SAD) is detailed in Table 4-17 of Reference
2. The results of theapplication of this process to NMP2 are summarized below.[[2-9 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION

-CLASS I (PUBLIC)2-10 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)]]The CDA setpoint calculation formula and the adjustable parameter values are defined in theDSS-CD LTR (Reference 2). In accordance with DSS-CD LTR SER Limitation andCondition 5.2 (Reference 2), the DSS-CD LTR, or GESTAR II including the approved DSS-CDLTR, is referenced in the proposed TS changes for implementation of DSS-CD.2.4.2 Armed Region2-11 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)]]The generic boundaries of the armed region were approved as part of the DSS-CD LTR.[[]] no further review of MELLLA+ is necessary to evaluate the adequacyof the armed region.Erno further review of MELLLA+ is necessary to evaluate the adequacy of the armedregion.Er2.4.3 Backup Stability Protection Er ]] the DSS-CD LTRdefines the BSP along with a generic process for confirming that the BSP requirements are metin each reload analysis. This BSP may be used when the OPRM system is temporarily inoperable. Implementation of DSS-CD per the DSS-CD LTR requires that the alternate stability protection approach is confirmed on a cycle-specific basis to demonstrate adequacy for eachreload cycle. no further review of MELLLA+ is necessary to evaluatethe adequacy of the BSP.Er NMP2 will incorporate theDSS-CD solution in accordance with the requirements of the DSS-CD LTR. Implementation ofDSS-CD in accordance with the DSS-CD LTR requires that NMP2 confirm the BSP approach isadequate as a part of the reload. [[]] no further review of BSP is required. Er2-12 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)2-13 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)2.5 REACTIVITY CONTROLThe control rod drive (CRD) system controls core reactivity by positioning neutron absorbing control rods within the reactor and scram the reactor by rapidly inserting control rods into thecore. No change is made to the control rods or drive system due to MELLLA+. The topicsaddressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultScram Time ResponseCRD Positioning and CoolingCRD Integrity 2.5.1 Control Rod Scram[ ]]forBWR/3, BWR/4, and BWR/5 plants the hydraulic control unit accumulators supply the initialscram pressure and, as the scram continues, the reactor becomes the primary source of pressureto complete the scram.]] the NMP2 hydraulic control unitaccumulators supply the initial scram pressure and, as the scram continues, the reactor becomesthe primary source of pressure to complete the scram. The NMP2 reactor dome pressure is1,035 psia (1,020 psig) and does not change as a result of MELLLA+ operating domainexpansion. [[2.5.2 Control Rod Drive Positioning and CoolingI As a result ofMELLLA+, there is no increase in temperature and [[]] Therefore, the CRD positioning and cooling functions are not affected byMELLLA+.[[ ]] for NMP2, the reactor coolanttemperature does not increase. [[2-14 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)2.5.3 Control Rod Drive Integrity []] thepostulated abnormal operating conditions for the CRD design assume a failure of the CRDsystem pressure-regulating valve that applies the maximum pump discharge pressure to the CRDmechanism internal components. This postulated abnormal pressure bounds the AmericanSociety of Mechanical Engineers (ASME) reactor overpressure limit. no further evaluation of CRD integrity is requiredas result of MELLLA+.ER the NMP2 CRD mechanism hasbeen analyzed for an abnormal pressure operation (the application of the maximum CRD pumpdischarge pressure) that bounds the ASME RPV overpressure condition. [[]] Also, as stated inSection 3.1.2, for the ASME RPV overpressure condition, the peak RPV bottom head pressure isunchanged and remains less than the limit of 1,375 psig. [[]] and no further evaluation of CRD integrity is required as result of MELLLA+.Er2.6 ADDITIONAL LIMITATIONS AND CONDITIONS RELATED TO REACTOR CORE AND FUELPERFORMANCE For that subset of limitations and conditions relating to Reactor Core and Fuel Design, which didnot fit conveniently into the organizational structure of the M+LTR, the required information ispresented here. The information is identified by either the M+LTR SER (Reference

1) limitation and condition or the Methods LTR SER (Reference
3) limitation and condition to which itrelates.2.6.1 TGBLA/PANAC VersionIn developing the NMP2 equilibrium core, the latest versions of TGBLA and PANAC were used.Refer to Table 1-1 for the latest revisions to TGBLA and PANAC. Cycle-specific analyses willinclude the most recent TGBLA and PANAC versions.

As required by Methods LTR SERLimitation and Condition 9.1, the most recent versions of TGBLA and PANAC are used.2.6.2 M+LTR SER Limitation and Condition 12.24.12-15 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)2.6.3 LHGR and Exposure Qualification Methods LTR SER Limitation and Condition 9.12 states that once the PRIME LTR(Reference

15) and its application are approved, future license applications for EPU andMELLLA+ referencing LTR NEDC-33173P-A must utilize the PRIME T-M methods.

ThePRIME LTR was approved on January 22, 2010 (Reference

15) and implemented in GESTAR IIin September 2010 (Reference 4). The NMP2 M+SAR has a PRIME T-M basis. PRIME fuelparameters have been used in all analyses requiring fuel performance parameters.

The T-M evaluation performed in support of the NMP2 M+SAR was performed using thePRIME T-M methodology. 2.6.4 GEXL-PLUS and Pressure Drop DatabaseThe applicability of the GE14 experimental GEXL-PLUS and pressure drop database isconfirmed for operation in the MELLLA+ domain.The Methods LTR NEDC-33173P-A (Reference

3) documents all analyses supporting theconclusions in this section that the application ranges of GEH codes and methods are adequate inthe MELLLA+ operating domain. In accordance with M+LTR SER Limitation andCondition 12.1, the range of mass fluxes and power/flow ratios in the GEXL database covers theintended MELLLA+ operating domain. The database includes low flow, high qualities, and voidfractions.

There are no restrictions on the application of the GEXL-PLUS correlation in theMELLLA+ operating domain.2-16 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Table 2-1 Peak Nodal Exposures Peak Nodal ExposurePlant Cycle (~IT(GWd/ST)A 18 38.849A 19 43.784B 9 56.359B 10 51.544C 7 53.447C 8 47.766D 13 56.660E 11 55.387F EQ- 120% 51.174NMP2 MELLLA+ 52.0032-17 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Table 2-2 Core Thermal Power to Core Flow Ratio at Steady-State andOff-Rated Conditions Operating Domain Core Thermal Power Core Flow Power-to-Flow RatioStatepoint* (MWt / %EPU) (Mlbm/hr / %rated) (MWt/MlbmI/hr) M/M+ Boundary "D" 3,988/100 107.4/99 37.13M+ Boundary "N" 3,988 / 100 92.2 / 85 43.24M+ Boundary "M" 3,095 / 77.6 59.7/55 51.86M/M+ Boundary "L" 2,727.8 / 68.4 59.7 / 55 45.71"*" Statepoints D, N, M, and L are shown in Figure 1-1.2-18 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Table 2-3 TLO and SLO DSS-CD Licensing Basis Generic Applicability EnvelopeChecklist Confirmation 2-19 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Table 2-4 [111Note: [[2-20 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Table 2-5 [111Note: [[2-21 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)8.07.5 '7 .0 -- ---- ----------'6.55.5--*-Plant A Cycle 18 m-Plant A Cycle 19 --.-Plant B Cycle 94.5 -o PlantBCyclelO 1 Plant C Cycle 7 --PlantCCydeB -*-Plant D Cycle13 -PlantECyclell -PlantF4.0, -*-NMP2 M ELLLA+0 2 4 6 8 10 12 14 16 18Cycle Exposure (GWDYST)Figure 2-1 Power of Peak Bundle versus Cycle Exposure2-22 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)1413~12E-6119)71-*-PlantA Cycle18 ---PlantA Cycle 19 -PlantB Cycle 9-4Plant B Cycle 10 -Plant C Cycle 7 -Plant C Cycle 8-PlantDCycle13 -PlantE Cycle 11 PPlantF-.--NM P2 M ELLLA+50 2 4 6 8 10 12Cycle Exposure (GWDIST)14 16 18Figure 2-2 Coolant Flow for Peak Bundle versus Cycle Exposure2-23 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)0.900.85W0.LL".0;0.75 -0.70-Plant A Cycle 18 --U- PlantA Cycle 19 ý-Plant B Cycle 9-Plant B Cycle 10 --PlantC Cycle 7 Plant C Cycle 8-Plant D Cycle 13 -PlantE Cycle 11 -Plant F--4-NMP2 MELLLA+I-0 2 4 6 8 10 12Cycle Exposure (GWDWS-)14 16 18Figure 2-3Exit Void Fraction for Peak Power Bundle versus Cycle Exposure2-24 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)0.900.85.X 0.85I-Lo.N0.750.70---Plant A Cycle 18-4Plant B Cycle 10--Plant D Cyclel3--NMP2 MELLLA+-u--Plant A Cycle 19-.--Plant C Cycle 7-Plant E Cycle 110 2 4 6 8 10 12Cycle Exposure (GWD/ST)14 16 18Figure 2-4Maximum Channel Exit Void Fraction versus Cycle Exposure2-25 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)t;L-49XUj=4)00,00.800.780.760.740.720.700.680.660.640.620.60--- -------- -------- --- --------------------- IN------------- 4 --------










--- ---------

--PlantA Cycle 18---PlantB Cycle 10PlantD Cycle 13--NMP2 MELLLA+-4w- Plant A Cycle 19-o-Plant C Cycle 7-Plant E Cycle 110 2 4 6 8 10 12Cycle Exposure (GWDIST)14 16 18Figure 2-5 Core Average Exit Void Fraction versus Cycle Exposure2-26 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)161412,=I------------------------





4.2-* PlantA Cycle 18 -PlantA Cycle 19* lPlantBCycle10

-PlantC Cycle7-Plant D Cycle 13 -Plant C Cycle 11---NM P2 M ELLLA+---Plant B Cycle 9Plant C Cycle 8-Plant FL ]00 2 4 6 8 10 12Cycle Exposure (GWDP'ST) 14 16 18Figure 2-6 Peak LHGR versus Cycle Exposure2-27 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)ab lob go- U*Imon ---------- jW4=9 ! "FlM Fs f W2 3 , S , 1 1 , .t iQ 0 14Figure 2-7 Dimensionless Bundle Power at BOC (200 MWd/ST)2-28 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Sm -t~p~m -,no u-I"ab imI~,r-,TiNcoma POWILf-WRX" $

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-CLASS I (PUBLIC)F3os in Qfm -t6 NNm Sm rvzo" 2s P-0b.~ ~ ,Figure 2-12 Bundle Operating LHGR (kW/ft) at EOC (18,577 MWd/ST)2-33 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Ai';,'A-.'ý ! -' PRAI " ...j 2rub. oo, nm*rCTP 22comecwlow I [toit1Figure 2-13 Bundle Operating MCPR at BOC (200 MWd/ST)2-34 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)FOO F- Fof :,_. -.FrLWAG(.00"i 2sFnnMT Vcow1I 2 ) 4 I.

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-CLASS I (PUBLIC)I AVAIXIUý' I I'.' FqrF___ mPcTV _- 4 As-L"u 'Il FEW mFKfur'izmm m ,Fo--n*m-,-F-m-F mi 2 B O4W 1E00 WMM1 3 S 4 6 I S I I U It 12 is 14 IFigure 2-16 Bundle Operating LHGR (kW/ft) at 15,000 MWdIST (Peak MFLPD Point)2-37 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)[ AFAIA-11,' I I'.' pqr__ý F3OR1- m 1d094"how I 2 9S13FA:_1IViFigure 2-17 Bundle Operating MCPR at 1,500 MWd/ST (Peak MFLCPR Point)2-38 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)viil a11w l Ilio1111so IIUIII~3E~ruU~I*IhhIII~~huIIUIflhIIII~u~lhEIUI~t2 -c ZItef 1111111ol 1111f:fi9sl vies 1:a411 u4 olil UipolFigure 2-18 Bundle Average Void History for Bundles with Low CPRs2-39 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Core Flow (Mlbm/hr) 0 10 20 30 40 50 60 70 80 90 100 110 120130120110100908070600 50403020100OPRM Armed Region------ .. ... --------..... The OPRM Armed Region is* defined by 75% drive flow. ."However the use of 75% coreflow is conservaive .450040003500300025002000150010005000T.. 7-__0 10 20 30 40 50 60 70 80 90 100 110Core Flow (%)120Figure 2-19 Required OPRM Armed Region2-40 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)3.0 REACTOR COOLANT AND CONNECTED SYSTEMSThis section addresses the evaluations that are applicable to MELLLA+.3.1 NUCLEAR SYSTEM PRESSURE RELIEF AND OVERPRESSURE PROTECTION The topics addressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultFlow-Induced Vibration i[Overpressure Relief Capacity3.1.1 Flow-Induced Vibration because there is no increase in the maximum main steam (MS) line flow for the MELLLA+operating domain expansion, there is no effect on the flow-induced vibration (FIV) of the pipingand SRVs during normal operation. [[]] for NMP2, maximum MS line(MSL) flow in the MELLLA+ operating domain does not increase. The numerical valuesshowing no increase in maximum steam flow rate are presented in Table 1-2. MELLLA+ doesnot result in any increase to the NMP2 maximum MSL flow, and there is no effect on the FIVexperienced by the SRVs or piping during normal operation. [[I]3.1.2 Overpressure Relief CapacityThe pressure relief system prevents overpressurization of the nuclear system during AOOs, theplant ASME upset overpressure protection event, and postulated ATWS events. The SRVsalong with other functions provide this protection. For NMP2, the limiting overpressure event isthe main steam isolation valve closure with scram on high flux (MSIVF) event. The peak RPVbottom head pressure is unchanged and remains less than the ASME limit of 1,375 psig.The SRV setpoint tolerance is independent of the MELLLA+ operating domain expansion. TheAOO, ASME overpressure, and ATWS response evaluations for MELLLA+ are performed usingexisting NMP2 SRV setpoint tolerances. The SRV setpoint tolerances are monitored at NMP2for compliance to the TS requirements. ]] Thereare no changes made to the NMP2 licensing basis for the ASME overpressure event.]] The SRV tolerance assumed in the NMP2 ASME overpressure event3-1 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)analysis is 3%. The tolerance is consistent with the actual SRV performance testing conducted on the NMP2 SRVs per TS Surveillance Requirement 3.4.4.1.Er]] There are no changes to theexisting licensing basis assumptions and code inputs used for the NMP2 ASME overpressure event analysis. The ASME overpressure analysis for NMP2 was performed at the 105% ICF core flowstatepoint, and at the 85% minimum CF statepoint using an approximate MELLLA+ equilibrium core. The analysis of the limiting overpressure event for NMP2 demonstrates that no change inoverpressure relief capacity is required. [[]] This process is unchanged by MELLLA+.3.2 REACTOR VESSELThe RPV structure and support components form a pressure boundary to contain reactor coolantand form a boundary against leakage of radioactive materials into the drywell (DW). The topicsaddressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultFracture Toughness Reactor Vessel Structural Evaluation 3.2.1 Fracture Toughness The MELLLA+ operating domain expansion results in a slightly higher operating neutron flux inthe upper portion of the core due to decreased water density. The effect of this water densityreduction is [[ ]] in peak vessel and peak shroud flux. Inaccordance with M+LTR SER Limitation and Condition 12.8, the MELLLA+ flux is calculated using the GEH flux evaluation methodology contained in NEDC-32983P-A (Reference 16),which is consistent with Regulatory Guide (RG) 1.190 (Reference

17) and was approved by theNRC in November 2005. The evaluation is based on an idealized equilibrium core loadingwhich is not a bounding core design. This core loading is intended to show general trends for thepurpose of comparison and demonstrating the anticipated effect on flux and fluence.

The NMP2RG 1.190 (Reference

17) fluence program monitors actual core operations to determine theeffect on fracture toughness.

The MELLLA+ operating domain flux distribution is assumed tobe similar to that of current licensed operating domain flux distribution, whereas the magnitude of flux level is proportional to the thermal power. The change to the NMP2 54 effective fullpower years (EFPYs) vessel internal diameter (ID) peak fluence as a result of implementing MELLLA+ is [[ 1]Key flux/fluence comparisons at 120% OLTP are provided in Table 3-1.Because there is no change to the NMP2 54 EFPY Vessel ID peak fluence as a result ofMELLLA+, there is no change to the beltline adjusted reference temperature (ART). The3-2 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)pressure/temperature curves do not require revision as a result of MELLLA+ operating domainexpansion. Because there is no change to the NMP2 54 EFPY Vessel ID peak fluence as a result ofMELLLA+, there is no change to the upper shelf energy (USE). NMP2 continues to meet the50 ft-lb requirement in 10 CFR 50, Appendix GBecause there is no change to the NMP2 54 EFPY Vessel ID peak fluence as a result ofMELLLA+, there is no change to the Weld Inspection Relief criteria for circumferential welds.Therefore, the inspection relief request does not require revision as a result of MELLLA+operating domain expansion. As a result of MELLLA+ there is no change in the NMP2 54 EFPY Vessel ID peak fluence.Therefore, there are no changes to the NMP2 ART, USE, or Weld inspection relief values as aresult of MELLLA+.3.2.2 Reactor Vessel Structural Evaluation [[]] there are no changes in the reactor operating

pressure, FW flow rate, or steamflow rates for the MELLLA+ operating domain expansion.

Other applicable mechanical loadsdo not increase for the MELLLA+ operating domain expansion. [[]] there is no change in the stress or fatigue for thereactor vessel components as a result of MELLLA+, and no further evaluation is required. [[ ]] for NMP2, there are no increases in the reactor operating

pressure, or maximum steam or FW flow rates for the MELLLA+operating domain expansion.

The numerical values showing no increases in reactor operating

pressure, or maximum steam or FW flow rates are presented in Table 1-2. Other NMP2mechanical loads do not increase as a result of the MELLLA+ operating domain expansion.

Therefore, there is no change in the stress and fatigue for the NMP2 reactor vessel components, and no further evaluation of NMP2 reactor vessel structural integrity is required. 3.3 REACTOR INTERNALS 3.3.1 Reactor Internal Pressure Differences The reactor internals include core support structure and non-core support structure components. The topics addressed in this evaluation are:3-3 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)M+LTRTopic Disposition NMP2 ResultFuel Assembly and Control Rod Guide Tube Lift Forces [[Reactor Internal Pressure Differences for Normal, Upset,Emergency and Faulted Conditions Reactor Internal Pressure Differences (Acoustic andFlow-Induced Loads) for Faulted Conditions Reactor Internals Structural Evaluation for Normal,Upset, and Emergency Conditions Reactor Internals Structural Evaluation for FaultedConditions Steam Dryer Separator Performance Steam Line Moisture Performance Specification ]]3.3.1.1 Fuel Assembly and Control Rod Guide Tube Lift Forces]] fuel assembly and CRGT lift forces are calculated for normal, upset, emergency, and faulted conditions consistent with the existing plant designbasis. There are no increases in the core exit steam flow, reactor operating

pressure, FW orsteam flow rates for the MELLLA+ operating domain expansion.

Because none of the preceding values change, the only remaining variable affecting the forces on the fuel assemblies andCRGTs for the normal, upset, emergency and faulted conditions in the MELLLA+ operating domain is the CF. Maximum CF is reduced in the MELLLA+ operating domain. [[]] Therefore, no further evaluation of fuel assembly or CRGT lift forces isrequired. [[ ]] for NMP2, the difference betweenthe 100% CLTP / 105% core flow ICF operation point core exit steam flow and the 100% CLTP/ 85% core flow MELLLA+ operation point core exit steam flow is essentially unchanged (lessthan a 0.4% increase). The differences between the vessel steam flow and FW flow rates for thetwo power-flow points are essentially unchanged, as well (both less than a 0.2% decrease). Thedome pressures for the two power-flow points are identical. The small differences between thecore exit steam flows, vessel steam flows and FW flow rates have a negligible effect on the fuelassembly and CRGT lift forces calculated for normal, upset, emergency and faulted conditions. Therefore, because the NMP2 CF at the MELLLA+ statepoint at 85% CF is less than the currentlicensed operating domain statepoint at 105% CF, the normal, upset, emergency and faulted fuelassembly and CRGT lift forces for the MELLLA+ operating domain [[3-4 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)]] and no further evaluation of these forces is required. I]3.3.1.2 Reactor Internal Pressure Differences for Normal, Upset, Emergency and FaultedConditions [[]] RIPDs (pressure differentials across the components) arecalculated for normal, upset, emergency and faulted conditions consistent with the existing plantdesign basis. There are essentially no changes in the core exit steam flow, reactor operating

pressure, FW or steam flow rates for the MELLLA+ operating domain expansion.

Because noneof the preceding values change, the only remaining variable affecting the RIPDs for the normal,upset, emergency and faulted conditions in the MELLLA+ operating domain is the CF.Maximum CF is reduced in the MELLLA+ operating domain. [[]] Therefore, no further evaluation of RIPDs for normal,upset, emergency and faulted conditions is required. [[ ]] for NMP2, the difference betweenthe 100% CLTP / 105% core flow ICF operation point core exit steam flow and the 100% CLTP/ 85% core flow MELLLA+ operation point core exit steam flow is less than a 0.4% increase. The differences between the vessel steam flow and FW flow rates for the two power-flow pointsare both less than a 0.2% decrease. The dome pressures for the two power-flow points areidentical. The small differences between the core exit steam flows, vessel steam flows and FWflow rates have a negligible effect on the RIPDs for normal, upset, emergency and faultedconditions. Therefore, because the NMP2 CF at the MELLLA+ statepoint at 85% CF is lessthan the current licensed operating domain statepoint at 105% CF, the normal, upset, emergency and faulted condition RIPDs for the MELLLA+ operating domain [[]] which includes ICF up to 105% RCF.]] and no further evaluation of thesepressure differentials is required for normal, upset, emergency and faulted conditions. 3.3.1.3 Reactor Internal Pressure Differences (Acoustic and Flow-Induced Loads) forFaulted Conditions As part of the RIPDs, the faulted acoustic and flow induced loads in the RPV annulus on jetpump, core shroud and core shroud support resulting from the recirculation line break LOCAhave been considered in the NMP2 evaluation. [[3-5 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)]] and NMP2 R[PDs for faulted conditions continueto be acceptable. [[3.3.2 Reactor Internals Structural Evaluation Structural integrity evaluations for MELLLA+ operating domain expansion are performed consistent with the existing design basis of the components. [[]] Therefore, no further structural evaluation of the reactor internals isrequired. An evaluation of the load categories applicable to the reactor internals under normal,upset, and emergency conditions is presented below:MELLLA+ ResultsLoad Category for Normal, Upset and Emergency Conditions Dead WeightSeismic (Operating BasisEarthquake (OBE))RIPDsFuel Assembly and CRGT LiftForcesContainment Dynamic Loads -(LOCA and SRV)Fuel Lift LoadsThermal Effects3-6 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)MELLLA+ ResultsLoad Category for Normal, Upset and Emergency Conditions Flow[[3.3.2.1 Reactor Internals Structural Evaluation for Faulted Conditions ]] The M+LTRalso defines that if the load conditions do not increase in the MELLLA+ operating domain, thenthe existing analysis results are bounding and no further evaluation is required. Applicable loads, load combinations, and service conditions are evaluated consistent with the plant designbasis for each component. As shown below, [[]] and thus no further evaluation is required. MELLLA+ ResultsLoad Category for Faulted Conditions Dead WeightSeismic (Safe ShutdownEarthquake (SSE))RIPDsFuel Assembly and CRGT LiftForcesContainment Dynamic Loads -(LOCA and SRV)Annulus Pressurization Jet ReactionFuel Lift LoadsFlowAcoustic and Flow-Induced LoadsDue To Recirculation Line Break3-7 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)The faulted condition loads for the NMP2 reactor internal components resulting from theMELLLA+ operating domain conditions [[1] no further evaluation for Reactor Internals Structural Evaluation for faulted conditions is required. 3.3.3 Steam Separator and Dryer Performance The performance of the NMP2 steam separator-dryer has been evaluated to determine themoisture content of the steam leaving the RPV. Compared to the current licensed operating domain (100% CF statepoint), the average separator inlet flow decreases and the averageseparator inlet quality increases at MELLLA+ conditions. These factors, in addition to the coreradial power distribution, affect the steam separator-dryer performance. Steam separator-dryer performance was evaluated at equilibrium cycle limiting conditions of high radial power peakingand 85% RCF to assess their capability to provide the quality of steam necessary to meetoperational criteria at MELLLA+ operating conditions. The evaluation of steam separator and dryer performance indicates that MCO increases atMELLLA+ conditions. This increase resulted in a MCO value above the original moistureperformance specification of 0.10 wt.%. Section 3.3.4 identifies a plant-specific moistureperformance specification based on as installed hardware. 3.3.4 Steam Line Moisture Performance Specification The effect of increased MCO on plant operation has been analyzed to verify acceptable steamseparator-dryer performance under MELLLA+ operating conditions for a maximum moisturecontent of 0.25 wt.%. MCO is monitored during operation to ensure adequate operating limitations are implemented as required to maintain MCO within analyzed conditions. Theamount of time NMP2 is operated with higher than the original design moisture content(0.10 wt.%) is minimized by operations. MCO monitoring periodicity is based upon results ofstartup testing, operating experience, control rod pattern and time in core life.The ability of the steam dryer and separator to perform their design functions during MELLLA+operation was evaluated. The NMP2 plant-specific evaluation concluded that the performance ofthe steam dryer and separator remains acceptable and the dryer skirt remains covered at L4, thelow water level alarm in the MELLLA+ region.MELLLA+ operation decreases the CF rate, resulting in an increase in separator inlet quality forconstant reactor thermal power. These factors, in addition to core radial power distribution, influence steam separator-dryer performance. NMP2's steam separator/dryer performance wasevaluated on a plant-specific basis to determine the influence of MELLLA+ on the steam dryerand separator operating conditions: (1) the entrained steam (i.e., carryunder) in the waterreturning from the separators to the reactor annulus region; (2) the moisture content in the steamleaving the RPV into the MSLs; and (3) the margin to dryer skirt uncovery. 3-8 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)The moisture content of the steam leaving the RPV increases in the MELLLA+ domain. Theeffect of the increase has been analyzed in the tasks that use the MCO value from Sections 3.3.3and 3.3.4. The effects of increased moisture are discussed in the following sections:

a. 3.5.1 Reactor Coolant Pressure Boundary Piping[R 1] as discussed inSection 3.3.3, the MCO may increase during the cycle when a plant is operating at ornear the MELLLA+ minimum CF rate.R[ ]] the MCO for NMP2 may increase to amaximum of 0.25 wt.% during the cycle when NMP2 is operating at or near theMELLLA+ minimum CF rate.b. 8.1 Liquid and Solid Waste Management Although the volume of waste generated is not expected to increase, potentially higherMCO in the reactor steam would result in a slightly higher loading on the condensate demineralizers.

Because the higher moisture content will occur infrequently, theMELLLA+ operating domain expansion will not cause the condensate demineralizer backwash frequency to be changed significantly as discussed in Section 8.1.2. Thereactor water cleanup (RWCU) filter demineralizer backwash frequency is not affectedbecause there is no effect on RWCU inlet conditions for MELLLA+, as discussed inSection 3.11.c. 8.4.2 Fission and Activation Corrosion ProductsSteam separator and dryer performance for MELLLA+ operation is discussed inSection 3.3.3. The moisture content of the MS leaving the vessel may increase up to0.25 wt.% at times while operating near the minimum CF in the MELLLA+ operating domain. The distribution of the fission and activated corrosion product activity betweenthe reactor water and steam is affected by the increased moisture content. With increased MCO, additional activity is carried over from the reactor water with the steam. Themaximum allowable moisture content leaving the reactor vessel is 0.25 wt.%.d. 8.5 Radiation LevelsAs discussed in Section 8.4, the moisture content of the MS leaving the vessel mayincrease at certain times while operating in the MELLLA+ operating domain. However,the NMP2 MCO will be monitored and controlled to < 0.25 wt.%, which is within theanalytical assumption of 0.35 wt.% used in the determination of normal operation radiation levels. The overall radiological effect of the increased moisture content is afunction of the plant water radiochemistry and the levels of activated corrosion productsmaintained.

e. 10.7.2 Flow Accelerated Corrosion The EPU flow accelerated corrosion (FAC) evaluation for MS and extraction steampiping assumed a 0.25 wt.% MCO for mechanical thermal conditions.

This 0.25 wt.%3-9 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)MCO value bounds the maximum predicted MCO value of 0.236 wt.% for MELLLA+based on equilibrium fuel cycle burnup assumptions. The predicted MCO is a function offuel loading and rod patterns throughout the burnup history. The MSIVs allowable moisture content was found to be acceptable for MELLLA+ operation based on GEHengineering

judgment, operating experience, and NMP2's MSIV inspection/maintenance program.

The increased moisture content will not create a significant change in wear onMS piping and components based on the evaluations performed using CHECWORKSTM and design assessments for the components. MCO will be managed with monitoring toidentify and track the duration of MCO above 0.1 wt.% based on taking chemicalsamples once per month. The FAC monitoring program was reviewed for potential changes to the program. No changes to the FAC program are required. The FAC relatedpiping and component wear is managed by the FAC program and Maintenance Rule asdiscussed in Section 10.7.2.f. 5.2.4 Main Steam Flow -FW Flow MismatchOperation at the higher MCO performance specification is acceptable. With a dryermoisture performance specification up to 0.35 wt.%, the additional coolant removed fromthe RPV must be returned to the reactor in order to maintain correct water level. The FWsystem may be required to provide a slightly higher flow rate. The effect of the increased MSL MCO is to cause a slight imbalance in the FW control system control point. With aplant bias of 0.48 inches per percent this translates to z 0.12 inches of bias in the waterlevel.g 3.4.1 Piping Components with Flow-Induced Vibration -Safety RelatedAdequate margin exists to the FIV of the sample probes and thermowells due to the largemargin available in the design.3.4 FLOW-INDUCED VIBRATION The FIV evaluation addresses the influence of the MELLLA+ operating domain expansion onreactor coolant pressure boundary (RCPB) piping, RCPB piping components, and RPV internals. The topics addressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultPiping FIV Evaluation Recirculation System PipingMain Steam PipingFeedwater PipingSafety-Related Thermowells and ProbesRPV Internals FIV Evaluation 3.4.1 FIV Influence on Piping]] Flow rates in the recirculation system3-10 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)piping, MS piping, and FW piping as well as associated MS and FW branch lines do not increaseas a result of MELLLA+ operating domain expansion. [[]] and no further evaluation of FIV influence on recirculation, MS,and FW piping is required. ]] For NMP2, there are noincreases in the recirculation system, MS, or FW flow rates as a result of MELLLA+ operating domain expansion as compared to the current licensed operating domain. The numerical valuesshowing no increases in recirculation system, MS, or FW flow rates are presented in Table 1-2.]] and no further evaluation ofFIV influence on recirculation, MS, and FW piping is required. ]] Because the flow rates inthese piping systems do not increase for MELLLA+, there is no increase in FIV for the safety-related thermowells and probes. [[]] and no further evaluation of FIV influence on safety-related thermowells and probes is required. Also, []] For NMP2, there is no increase in flowin these systems for MELLLA+. Therefore, there is no increase in FIV for the safety-related thermowells and probes. [[]] and no further evaluation of FIVinfluence on safety-related thermowells and probes is required. 3.4.2 FIV Influence on Reactor Internals Er evaluates the effect of theMELLLA+ operating domain expansion on the following components: shroud, shroud head andsteam separator-dryer, core spray (CS) line, low pressure coolant injection (LPCI) coupling, CRGT, in-core guide tubes, fuel channel, LPRM / intermediate range monitor (IRM) tubes, jetpumps, jet pump sensing lines (JPSLs), and FW sparger. The MELLLA+ operating domainexpansion results in decreased core and recirculation flow as well as no increase in the MS and3-11 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)FW flow rates. [[]] the effect of the MELLLA+operating domain expansion is presented for the following components: Component(s) MELLLA+ ResultsShroudShroud Head and SteamSeparator-Dryer CS LineLPCI CouplingCRGTIn-Core Guide TubesFuel ChannelLPRM/IRM TubesJet PumpsJPSLsFW SpargerFor NMP2, the MELLLA+ operating domain expansion results in decreased core andrecirculation flow as well as no increase in the MS and FW flow rates. The numerical valuesshowing a decrease in core and recirculation flow as well as no increase in maximum steam orFW flow rates are presented in Table 1-2. As presented in the table above, [[]] The reduced CF and recirculation flow3-12 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)in the MELLLA+ domain [[]] Therefore, no further evaluation of the FIV influence on reactor internals isrequired for the NMP2 MELLLA+ operating domain expansion. Er3.5 PIPING EVALUATION 3.5.1 Reactor Coolant Pressure Boundary PipingThe RCPB piping systems evaluation consists of a number of safety-related piping subsystems that move fluid through the reactor and other safety systems. The topics addressed in thisevaluation are:Topic M+LTR Disposition NMP2 ResultMain Steam and Feedwater (Inside Containment) Recirculation and Control Rod DriveReactor Core Isolation Cooling (RCIC)High Pressure Core Spray (HPCS)RWCULow Pressure Core Spray (LPCS)Standby Liquid ControlResidual Heat Removal (RHR)RPV Head Vent LineSRV Discharge Line (SRVDL)Safety-Related Thermowells The piping systems are required to comply with the structural requirements and Pressure Vessel (BPV) Code (or an equivalent Code) applicable at theor the governing code used in the stress analysis for a modified component. of the ASME Boilertime of construction 3.5.1.1 Main Steam and Feedwater Piping Inside Containment Er]] the system temperatures, pressures, and flows in the MELLLA+operating domain are within the range of rated operating parameters for the MS and FW pipingsystem (inside containment). [[1]the temperatures, pressures, and flows in MS and FW systems for MELLLA+ operation are3-13 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)within the range of rated operating parameters for those systems, no further evaluation isrequired related to RCPB piping for MS and FW piping inside containment. [[ ]] for NMP2, the MS and connected branch piping (i.e., RCIC steam lines) and FW temperatures, pressures, and flows are within therated operating parameters for the MS and FW systems. MS and FW temperatures, flows, andpressures at MELLLA+ conditions are bounded by the EPU temperatures, flows, and pressures, and as such are within the design values used in the design of the piping and supports chosen forworst case conditions. NMP2 MS and FW piping inside containment is designed in accordance with the original code of record, ASME BPV Code, Section III, Subsection NB, 1974 Edition.[[]] the temperatures, pressures, and flows in NMP2 MS and FWsystems for MELLLA+ operation are within the range of rated operating parameters for thosesystems, and no further evaluation is required related to the NMP2 RCPB piping for MS and FWinside containment. [I ]] as discussed in Section 3.3.3,the MCO may increase during the cycle when a plant is operating at or near the MELLLA+minimum CF rate. The generic disposition concludes that the change in erosion/corrosion ratesas a result of increased carryover is adequately managed by the existing programs discussed inSection 10.7.2.Er ]], the MCO for NMP2 may increase to a maximumof 0.25 wt.% during the cycle when NMP2 is operating at or near the MELLLA+ minimum CFrate. NMP2 implements programs adequate to manage this change in the erosion/corrosion rateas described in Section 10.7.2.The effect of MELLLA+ on the EPU AP load SC 09-01 evaluation has determined that theamplified response spectra (ARS) remains conservative for the rated power MELLLA+ Point N(Figure 1-1). The off-rated SC 09-01 methods show minor shifts in the ARS for selected nodes(power-flow map Points A and N in Figure 1-1) as compared to the EPU bounding spectrum. The review of the EPU SC 09-01 AP load assessments show the minor shifts represent aninsignificant change in the total load combination for these piping systems such that theconclusions reached for the EPU assessment remain unchanged. 3.5.1.2 Reactor Recirculation and Control Rod Drive Systems]] there is no change in the maximum operating systemtemperatures, pressures, and flows in the MELLLA+ operating domain for the recirculation piping system and attached RHR piping system. [[3-14 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)]] no further evaluation of the RCPB piping -reactor recirculation and CRDsystems is required for MELLLA+ operating domain expansion. [[ ]] for NMP2, the reactorrecirculation and CRD system temperatures, flows, and pressures at MELLLA+ conditions arebounded by the EPU temperatures, flows, and pressures, and as such are within the design valuesused in the design of the piping and supports chosen for worst case conditions. 3.5.1.3 Other RCPB Piping Systems3.5.1.3.1 Other RCPB Piping Systems -HPCS, LPCS, RHR/LPCI, and SLS]] Because the piping systems meeting the criteria [[]] their susceptibility toerosion/corrosion does not increase, and no further evaluation of these other RCPB pipingsystems is required. [[ ]] MELLLA+ operating domainexpansion for NMP2 does not change the maximum operating temperature,

pressure, or flow rateof any of the following systems:

HPCS, LPCS, RHR/LPCI, and SLS.HPCS, LPCS, RHR/LPCI, and SLS temperatures, flows, and pressures at MELLLA+ conditions are bounded by the EPU temperatures, flows, and pressures, and as such are within the designvalues used in the design of the piping and supports chosen for worst case conditions. Each of these NMP2 systems [[]] their susceptibility toerosion/corrosion does not increase, and no further evaluation of these other RCPB pipingsystems is required for NMP2.3.5.1.3.2 Other RCPB Piping Systems -RPV Head Vent Line and SRV Discharge Lines[[3-15 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)]] For the RPV head vent line and theSRVDL, there is no change in the temperature,

pressure, or flows in these systems as a result ofMELLLA+ operating domain expansion.

Because the piping systems have no change in systemtemperature, pressure or flow as a result of MELLLA+ operating domain expansion, [[]] Their susceptibility to erosion/corrosion does not increase, andno further evaluation of these other RCPB piping systems is required. [[ ]] MELLLA+ operating domainexpansion for NMP2 does not change the maximum operating temperature,

pressure, or flow rateof any of the following piping systems:

RPV head vent line and SRVDL.RPV head vent line and SRVDL temperatures, flows, and pressures at MELLLA+ conditions arebounded by the EPU temperatures, flows, and pressures, and as such are within the design valuesused in the design of the piping and supports chosen for worst case conditions. Additionally, there is no flow through the SRVDL during normal operating conditions. The RPV head vent line and the SRVDL are unaffected by MELLLA+ operating domainexpansion. [[ ]] their susceptibility to erosion/corrosion does not increase, and no further evaluation of these other RCPB piping systems is required forNMP2.3.5.1.3.3 Other RCPB Piping Systems -RWCU[[]] Because the RWCU system has no change insystem temperature, pressure or flow as a result of MELLLA+ operating domain expansion, [[]] RWCU system susceptibility to erosion/corrosion does notincrease, and no further evaluation of the RWCU system is required. Er ]] MELLLA+ operating domainexpansion for NMP2 does not change the maximum operating temperature,

pressure, or flow rateof the RWCU system. RWCU system temperatures, flows, and pressures at MELLLA+conditions are bounded by the EPU temperatures, flows, and pressures, and as such are withinthe design values used in the design of the piping and supports chosen for worst case conditions.

The NMP2 RWCU system is unaffected by MELLLA+ operating domain expansion. Er ]] the RWCU system susceptibility toerosion/corrosion does not increase, and no further evaluation of the RWCU system is required. 3.5.1.3.4 Other RCPB Piping Systems -Safety-Related Thermowells [[]] Because the RCPB pipingsystems evaluated for EPU do not experience any increase in pressure, temperature, or flow atMELLLA+, their susceptibility to erosion/corrosion does not increase, and no further evaluation of safety-related thermowells is required for NMP2.3-16 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)]] the NMP2 safety-related thermowells are unaffected by MELLLA+ as the evaluations performed for the currently licensed operating domain are bounding for MELLLA+ conditions. [[Their susceptibility to erosion/corrosion does not increase and no further evaluation of safety-related thermowells is required for NMP2.Because all of the piping systems in Section 3.5.1.3 meet the criteria listed [[]] their susceptibility toerosion/corrosion does not increase, and no further evaluation of these other RCPB pipingsystems is required. 3.5.1.4 Other than Category "A" RCPB MaterialAs required by M+LTR SER Limitation and Condition 12.9, the following discussion ispresented regarding other than Category "A" materials that exist in the RCPB piping.Category "A" is assumed to mean intergranular stress corrosion cracking (IGSCC) Category "A"that is a resistant material to IGSCC for BWR piping weldments in accordance with GenericLetter (GL) 88-01 (Reference 18). Other than Category "A" is assumed to mean non-resistant orcracked materials for IGSCC BWR piping weldments in accordance with GL 88-01 (IGSCCCategories B through G). USAR Section 5.2-5 is only a general RCPB list and is not specifically related to IGSCC. The SER for GL 88-01, along with the associated technical evaluation, establishes the IGSCC categories and initial IGSCC related bases. The current IGSCC programis located within the in-service inspection (ISI) program plan (CNG-NMP2-ISI-003). CNG-NMP2-ISI-003, Section 6.1 specifically identifies 49 welds that are in the IGSCC otherthan Category "A" (Categories D and E shown in Tables 6-1 and 6-2 and summarized inTable 6-5 and Appendix E). CNG-NMP2-ISI-003-10 shows the implementation schedule andhas the "ASME Section XI Category Item No." column as either "GLD" or "GL-E," whichidentifies the location of the weld.The NMP2 ISI program for all ASME Code Class 1 and 2 RCPB piping is in accordance with anNRC staff approved alternate risk-informed inspection program utilizing the NRC approvedElectric Power Research Institute (EPRI) methodology, Technical Report TR-1 12657,Revision B-A (Reference 19). In addition to the ASME Code, Section XI and the alternate risk-informed

programs, NMP2 implements an augmented IGSCC inspection program in accordance with GL 88-01 (Reference 18), NUREG-0313 (Reference 20), and as modified by Boiling WaterReactor Vessel and Internals Project (BWRVIP)-75 (Reference
21) for IGSCC Category D weldexamination frequency using normal water chemistry.

NMP2 implements ASME Section XI,Appendix VIII for the performance demonstration for ultrasonic examination systemsadministrated through the EPRI performance demonstration initiative (PDI) program.Appendix VIII provided the requirements for the performance demonstration for ultrasonic examination procedures, equipment, and personnel to detect and size flaws. All of the above3-17 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)programs have been credited as an aging management program during the NMP2 license renewalprocess.Continued implementation of the current program ensures the prompt identification of anydegradation of RCPB components experienced during MELLLA+ operating conditions. [[ ]] confirms that the augmented inspection programat NMP2 is adequate to address concerns related to other than Category "A" materials in theRCPB.3.5.2 Balance-of-Plant PipingThe BOP piping evaluation consists of a number of piping subsystems that move fluid throughsystems outside the RCPB. The topics considered in this section are:Topic M+LTR Disposition NMP2 ResultMain Steam and Feedwater (Outside Containment) Reactor Core Isolation CoolingHigh Pressure Core SprayLow Pressure Core SprayResidual Heat RemovalHigh Pressure Coolant Injection (HPCI)Offgas SystemContainment Air Monitoring Neutron Monitoring System3.5.2.1 Main Steam and Feedwater (Outside Containment) [[]] for all MS and FW piping systems, including the associated branch piping, thetemperature,

pressure, flow, and mechanical loads do not increase due to the MELLLA+operating domain expansion.

[[]] The susceptibility of these piping systemsto erosion/corrosion increases only for the MS piping; however, that erosion/corrosion will beadequately managed as discussed in Sections 3.5.1.1 and 10.7.2. [[no further evaluation is required for BOP Piping -MS and FW(outside containment). [ MELLLA+ operating domainexpansion for NMP2 does not change (no increase) the maximum operating temperature,

pressure, flow rate, or mechanical loads for the MS and FW piping outside containment.

MS andFW system temperatures, flows, and pressures at MELLLA+ conditions are bounded by the EPUtemperatures, flows, and pressures, and as such are within the design values used in the design of3-18 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)the piping and supports chosen for worst case conditions. The NMP2 MS and FW piping outsidecontainment is unaffected by the MELLLA+ operating domain expansion. The NMP2 BOPpiping outside containment was typically designed in accordance with American NationalStandards Institute (ANSI) B331.1 (Reference

22) and as such, there were no fatigue analysesrequired or performed.

[[]], theFW piping outside containment susceptibility to erosion/corrosion does not increase, and nofurther evaluation is required. The MS outside containment susceptibility to erosion/corrosion does increase;

however, no further evaluation is required due to being adequately managed asdiscussed in Sections 3.5.1.1 and 10.7.2.i3.5.2.2 Other BOP Piping Systems3.5.2.2.1 Other BOP Piping Systems -RCIC, HPCS, LPCS, and RHR the loads and temperatures used in the analyses depend onthe containment hydrodynamic loads and temperature evaluation results (Section 4.1). [[]] The design basis LOCA dynamic loads including the pool swell loads, ventthrust loads, condensation oscillation (CO) loads, and chugging loads have been defined andevaluated for EPU. The pool temperatures due to a design basis LOCA were also defined forEPU. The values for the MELLLA+ operating domain remain within these bounding values.[[]] For these BOP piping systems,no further evaluation is required as a result of MELLLA+.The effect of MELLLA+ on the EPU AP load SC 09-01 evaluation has determined that the ARSremains conservative for the rated power MELLLA+ Point N (Figure 1-1). The off-rated SC 09-01 methods show minor shifts in the ARS for selected nodes (power-flow map Points Aand N in Figure 1-1) as compared to the EPU bounding spectrum.

The review of the EPUSC 09-01 AP load assessments show the minor shifts represent an insignificant change in thetotal load combination for these piping systems such that the conclusions reached for the EPUassessment remain unchanged. The MELLLA+ operating domain expansion for NMP2 does not change the maximum operating temperature,

pressure, or flow rate, or increase mechanical loads for any of the following systems:

RCIC, HPCS, LPCS, and RHR.RCIC, HPCS, LPCS, and RHR system temperatures, flows, and pressures at MELLLA+conditions are bounded by the EPU temperatures, flows, and pressures, and as such are withinthe design values used in the design of the piping and supports chosen for worst case conditions. ]] for each of the NMP2 systems described above, theloads and temperatures used in the analyses continue to be bounded by the loads and3-19 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)temperatures used in the analyses performed for EPU. Section 4.1 shows that the NMP2 LOCAdynamic loads including the pool swell loads, vent thrust loads, CO loads, and chugging loadshave been evaluated and are bounded by the current design basis. The NMP2 peak suppression pool temperatures due to a design basis LOCA are also bounded by the current design basis.]] For these BOP pipingsystems, no further evaluation is required as a result of MELLLA+.3.5.2.2.2 Other BOP Piping Systems -Offgas System, Containment Air Monitoring, and Neutron Monitoring System]] For these BOP piping systems, no further evaluation is required as a result ofMELLLA+.[[ ]] there is no change to the NMP2reactor operating pressure or power level as a result of MELLLA+ operating domain expansion. The numerical values showing no increases in reactor operating pressure are presented inTable 1-2. [[]] For theseBOP piping systems, no further evaluation is required as a result of MELLLA+.Because all of the piping systems in Section 3.5.2.2 meet the criteria listed [[]] theirsusceptibility to erosion/corrosion does not increase, and no further evaluation of these otherBOP piping systems is required. I[[3.6 REACTOR RECIRCULATION SYSTEMThe topics addressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultSystem Evaluation [[Net Positive Suction Head (NPSH)Single Loop Operation Flow Mismatch _ E3.6.1 System Evaluation [[ ]] all of theRRS operating conditions for the MELLLA+ operating domain are within the operating conditions in the current licensed operating domain. SLO is not allowed in the MELLLA+3-20 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)operating domain. [[]] and no further evaluation of this topic is required. ]] the NMP2 RRS operating conditions in the MELLLA+ operating domain are within the operating conditions in the currentlicensed operating domain. For NMP2, there are no increases beyond design rated parameters inthe RRS temperature,

pressure, or flow rates as a result of MELLLA+ operating domainexpansion as compared to the current licensed operating domain. RRS system temperature forthe current licensed operating domain at 100% CF is 533.7°F and in the MELLLA+ operating domain at 85% CF is 530.7°F.

RRS system pressures, at the discharge of the recirculation pump,will increase from 1,314.5 psia for the current licensed operating domain to 1,340.5 psia in theMELLLA+ operating domain. This slight increase in pressure is due to the adjustment of theFCV to approximately the 59% opened position and is within the design operating pressure ofthe RRS system components. The numerical values showing no increases in RRS system flowrates are presented in Table 1-2. For NMP2, SLO is not allowed in the MELLLA+ operating domain. [[]] and no further evaluation ofthis topic is required. 3.6.2 Net Positive Suction Head]] Therefore, no further evaluation of the RRS NPSH topic is required. 3-21 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)]] flow rate and FW temperature and, as described above, they are not changed by MELLLA+. [[]] The numerical values showing no significant changes in FW temperature and flow are presented in Table 1-2. Therefore, no furtherevaluation of the RRS NPSH topic is required. 3.6.3 Single Loop Operation [[ ]] SLO is notallowed in the MELLLA+ operating domain.[[ ]] SLO is not allowed in the MELLLA+ operating domain. NMP2 SLO operational limitations will be identified in TS 3.4.1. Therefore, SLO isnot allowed in the MELLLA+ operating range and is not affected by the MELLLA+ domainexpansion. 3.6.4 Flow MismatchFlow mismatch is discussed in Section 4.3.8.3.7 MAIN STEAM LINE FLOW RESTRICTORS The topics addressed in this evaluation are:Topic " M+LTR Disposition NMP2 ResultStructural Integrity ]] there is no increase in MS flow as a result of the MELLLA+ operating domainexpansion. [[]] and no further evaluation of this topic is required. ]] there is no increase in NMP2 MS flow as a resultof MELLLA+ operating domain expansion. The numerical values showing that MS flow doesnot increase as a result of MELLLA+ are presented in Table 1-2. [[]] and no further evaluation ofthis topic is required. 3-22 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)3.8 MAIN STEAM ISOLATION VALVESThe topics addressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultIsolation Performance Valve Pressure Drop ]]]] there is no increase inMS pressure, flow, or pressure drop as a result of the MELLLA+ operating domain expansion. [[ ]]and no further evaluation of this topic is required. [[ ]] there is no significant change in NMP2 MSpressure, flow, or pressure drop as a result of MELLLA+ operating domain expansion. The MSpressure for the current licensed operating domain and in the MELLLA+ operating domain is1,035 psia. The numerical values showing that MS flow does not increase as a result ofMELLLA+ are presented in Table 1-2. The total MSL pressure drop at the TSVs is notsignificantly changed for MELLLA+; the MSIV pressure drop is also not significantly changed.i and no further evaluation of this topic is required. 1]3.9 REACTOR CORE ISOLATION COOLINGThe RCIC system provides inventory makeup to the reactor vessel when the vessel is isolatedfrom the normal high pressure makeup systems. The topics addressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultSystem Hardware [[System Initiation Net Positive Suction HeadInventory Makeup Level Margin to Top of Active Fuel (TAF) F3.9.1 System Hardwarethere are no changes to the RCIC system hardware as a result of MELLLA+ operating domainexpansion. [[ ]] there are no changes to the NMP2 RCIC systemhardware as a result of MELLLA+.3-23 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)3.9.2 System Initiation [[ ]] thereare no changes to the normal reactor operating

pressure, decay heat, or SRV setpoints as a resultof MELLLA+ operating domain expansion.

[[no further evaluation of this topic is required. ]] there are no changes to the normal reactoroperating

pressure, decay heat, or SRV setpoints as a result of MELLLA+ operating domainexpansion.

The NMP2 reactor operating pressure for the current licensed operating domain andin the MELLLA+ operating domain remain unchanged. The numerical values showing thatreactor operating pressure does not increase as a result of MELLLA+ are presented in Table 1-2.As described in Section 1.2.3, the generic disposition in the M+LTR concludes that there is noincrease in decay heat as a result of MELLLA+ operating domain expansion. As discussed inSection 3.1.2, SRV setpoints are unchanged by MELLLA+ operating domain expansion. Therefore, for NMP2, [[]] No further evaluation of this topic is required. 3.9.3 Net Positive Suction Head[[ ]] the NPSHavailable for the RCIC pump [[]] For ATWS(Section 9.3) and fire protection (Section 6.7), operation of the RCIC system at suppression pooltemperatures greater than the operational limit may be accomplished by using the CST volume asthe source of water. Therefore, the specified operational temperature limit for the process waterdoes not change with MELLLA+. The NPSH required by the RCIC pump [[]] Therefore, no further evaluation is required for this topic.]] for NMP2, there are no physical changes to thepump suction configuration. The NMP2 RCIC flow rate for the current licensed operating domain and in the MELLLA+ operating domain is 600 gpm. Minimum atmospheric pressure in3-24 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)the suppression chamber and the CST for the current licensed operating domain and in theMELLLA+ operating domain does not change. The RCIC system has the capability of using theCST or the suppression pool as a suction source at EPU and MELLLA+ conditions. For ATWS(Section 9.3) and fire protection (Section 6.7), operation of the RCIC system at suppression pooltemperatures greater than the operational limit may be accomplished by using the CST volume asthe source of the water. Therefore, the specified operational temperature limit for the processwater does not change with MELLLA+. In addition, the MELLLA+ suppression pooltemperature following an ATWS is bounded by EPU.The design basis function of the RCIC system is to provide coolant to the reactor vessel so thatthe core is not uncovered as a result of loss of off-site alternating current (AC) power or for aloss of feedwater (LOFW) event.The NPSH required by the NMP2 RCIC pump [[]] Therefore, no furtherevaluation is required for this topic.3.9.4 Inventory Makeup Level Margin to TAFThe makeup capacity of RCIC and the level margin to the TAF are evaluated in Section 9.1.3.3.10 RESIDUAL HEAT REMOVAL SYSTEMThe RHR system is designed to restore and maintain the reactor coolant inventory following aLOCA and remove reactor decay heat following reactor shutdown for normal, transient, andaccident conditions. The topics addressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultLow Pressure Coolant Injection ModeSuppression Pool and Containment Spray Cooling ModesShutdown Cooling (SDC) ModeSteam Condensing ModeFuel Pool Cooling Assist ]]The primary design parameters for the RHR system are the decay heat in the core and theamount of reactor heat discharged into the containment during a LOCA. The RHR systemoperates in various modes, depending on plant conditions. [[]]3.10.1 Low Pressure Coolant Injection ModeThe LPCI mode, as it supports the LOCA response, is discussed in Section 4.2.4, Low PressureCoolant Injection. 3-25 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)3.10.2 Suppression Pool and Containment Spray Cooling Modes]] the SPC mode is manually initiated to maintain thecontainment pressure and suppression pool temperature within design limits following isolation transients or a postulated LOCA. The short-term containment

response, for the first 30 secondsof the event, does not credit the containment spray in the analyses.

[[]] Therefore, no further evaluation is required for this topic.3.10.3 Shutdown Cooling Mode[]] theSDC mode is designed to remove the sensible and decay heat from the reactor primary systemduring a normal reactor shutdown. This non-safety related mode allows the reactor to be cooleddown within a certain time, so that the SDC mode of operation does not become a critical pathduring refueling operations. [[]] Therefore, no further evaluation is required for this topic.3.10.4 Steam Condensing ModeThe steam condensing mode is not applicable to NMP2.3.10.5 Fuel Pool Cooling Assist ModeThe fuel pool cooling assist mode, using existing RHR heat removal capacity, providessupplemental fuel pool cooling in the event that the fuel pool heat load exceeds the capability ofthe fuel pool cooling and cleanup system. [[]] Therefore, there is no effect on the fuel poolcooling assist mode.3.11 REACTOR WATER CLEANUP SYSTEMThe topics addressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultSystem Performance [[Containment Isolation 3-26 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)3.11.1 System Performance ER]] the MELLLA+ operating domain expansion does not change the pressure or fluidthermal conditions experienced by the RWCU system. Operation in the MELLLA+ operating domain does not increase the quantity of fission products, corrosion

products, and other solubleand insoluble impurities in the reactor water. Reactor water chemistry is within fuel warrantyand TS limits on effluent conductivity and particulate concentration, and thus, no changes will bemade in water quality requirements.

[[ ]] for NMP2, there is no totalincrease in the quantity of fission products, corrosion

products, and other soluble and insoluble radionuclide impurities in the reactor water (see Section 8.4). Consistent with the genericdisposition discussed above, for NMP2, there is no significant change in the FW linetemperature,
pressure, or flow rate. FW line temperature for the current licensed operating domain and in the MELLLA+ operating domain is 440.5'F (upstream of the RWCU return).

Asshown in Table 1-2, the FW flow rate in the MELLLA+ operating domain decreases slightlyfrom the flow rate in the current licensed operating domain. As discussed in Section 1.2, reactorpressure for the current licensed operating domain and in the MELLLA+ operating domain doesnot change. Therefore, FW system resistance and operating conditions do not change and thepressure at the RWCU/FW system interface does not change. As discussed in Sections 1.2 and3.6, reactor and recirculation system parameters are bounded by or unchanged from EPUconditions. Therefore, there is no effect on RWCU inlet conditions due to MELLLA+. Becausethere is no change to the pressure or fluid thermal conditions experienced by the RWCU system,and because there is no total increase in the quantity of fission products, corrosion

products, andother soluble and insoluble radionuclide impurities in the reactor water, [[]] Therefore, no further evaluation of this topic is required.

3.11.2 Containment Isolation ]] the RWCU system is a normally operating system with no safety-related functions otherthan containment isolation. [[]] because there is no change in the FW line pressure, temperature, and flow rate.[[ ]] for NMP2, there is no significant change in the FW line temperature,

pressure, or flow rate. The FW line temperature for thecurrent licensed operating domain and in the MELLLA+ operating domain is 440.5'F (upstream of the RWCU return).

As shown in Table 1-2, the maximum FW flow rate in the MELLLA+operating domain decreases slightly from the maximum flow rate in the current licensedoperating domain. As such, the FW flow rates in the MELLLA+ operating domain remain3-27 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)within the FW flow rates in the current licensed operating domain. As discussed in Section 1.2,reactor pressure for the current licensed operating domain and in the MELLLA+ operating domain does not change. Therefore, FW system resistance and operating conditions do notchange and the pressure at the RWCU/FW system interface does not change for RWCU returnlines. As discussed in Section 3.11.1 above, there is no change to RWCU inlet conditions. 3-28 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Table 3-1 Key Results at 120% OLTPItem Parameter CLTP to M+120% OLTP Comparison I Azimuthal flux distribution at RPV ID Ratio of M+/CLTP peak flux is 0.982 Relative axial flux distribution at RPV ID No significant change3 Azimuthal flux distribution at shroud ID Ratio of M+/CLTP peak flux is 1.014 Relative axial flux distribution at shroud ID No significant change5 54-EFPY axial fluence distribution at RPV ID Ratio of M+/CLTP peak fluence is 0.996 54-EFPY axial fluence at shroud H4 weld Ratio of M+/CLTP peak fluence is 1.027 Capsule (30 azimuth) flux Ratio of M+/CLTP flux is 1.028 Capsule lead factor Ratio of M+/CLTP lead factor is 1.059 Peak flux at top guide Ratio of M+/CLTP peak flux is 1.0710 Peak flux at core plate Ratio of M+/CLTP peak flux is 0.9411 54-EFPY peak fluence at top guide Ratio of M+/CLTP peak fluence is 1.0612 54-EFPY peak fluence at core plate Ratio of M+/CLTP peak fluence is 0.943-29 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)4.0 ENGINEERED SAFETY FEATURESThis section addresses the evaluations that are applicable to MELLLA+.4.1 CONTAINMENT SYSTEM PERFORMANCE The topics addressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultShort-Term Pressure and Temperature ResponseLong-Term Suppression Pool Temperature ResponseContainment Dynamic LoadsLoss-of-Coolant Accident LoadsSubcompartment Pressurization Safety Relief Valve LoadsSafety Relief Valve Containment Dynamic LoadsSafety-Relief Valve Piping LoadsContainment Isolation Generic Letter 89-10Generic Letter 95-07Generic Letter 96-064.1.1 Short-Term Pressure and Temperature ResponseAccording to Section 4.1.1 of the M+LTR (Reference 1), operation in the MELLLA+ range maychange the break energy for the DBA recirculation suction line break (RSLB). The break energyis derived from the break flow rate and enthalpy. [[]] NMP2 short-term RSLB containment temperature and pressure responses are affected by the change in enthalpy as a result of MELLLA+ operating domain expansion. The short-term RSLB analyses cases at MELLLA+ demonstrate that peak DW temperatures from the short-term RSLB for the current licensed operating domain and the MELLLA+operating domain are bounded by the CLTP results reported in Reference 23 which remainbelow the design limit of 340'F.For NMP2, there are two peak pressures; the first peak occurring -25 seconds (end of initialvessel inventory blowdown) and the second peak occurring -150 seconds (end of blowdownphase). The first peak is typically determined by standard short-term

analysis, while the secondpeak is determined by the extended short-term analysis.

The first peak is lower than the secondpeak; the difference is -0.5 psi for EPU. The extended short-term analysis is not sensitive to thesubtle initial changes in vessel mass and energy associated with operation at various points in theoperating domain. Due to the extended time frame until the DW reaches the second peakpressure conditions, it is recognized that the minor variability in the initial vessel inventory energy associated with various points in the operating range would have negligible effect in4-1 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)comparison to the overall mass and energy contributions to the DW at the time of the secondpeak. Therefore, the effect of MELLLA+ is assessed from the results of the standard short-term analysis using more detailed LAMB break flow model, which captures the subcooling effectwhen operating in MELLLA+ operating domain. Several short-term cases are analyzed forMELLLA+ statepoints and results compared to EPU short-term results. The results show thatEPU short-term peak pressure bounds the MELLLA+ peak pressures. The peak DW-to-wetwell differential pressures for operation in the MELLLA+ operating domain are bounded by thosepreviously reported in Reference 23 for the current CLTP operation. [[]]4.1.1.1 Long-Term Suppression Pool Cooling Temperature ResponseTherefore, no further evaluation of this topic is required. [[ ]] the sensible and decay heat do notincrease as a result of MELLLA+ operating domain expansion. [[]] No further evaluation of thistopic is required. 4.1.2 Containment Dynamic Loads4.1.2.1 Loss-of-Coolant Accident LoadsAs described in the M+LTR, a [[ ]] evaluation is performed to determine theeffect of MELLLA+ on the LOCA containment dynamic loads. Results from [[]] are used to evaluate the effect of the MELLLA+ operating domain expansion onLOCA containment dynamic loads. The LOCA dynamic loads include vent clearing jet loads,pool swell, CO, and chugging. 4-2 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)These loads have been defined generically for Mark II plants as part of the Mark II containment program and are described in detail in the Mark II Containment Dynamic Forcing Functions Report (DFFR) (Reference 24). The DFFR was reviewed and approved by the NRC inNUREG-0808 and NUREG-0487 (References 9 and 25). The specific application of these loadsto NMP2 is described in Section 6A.4 of the NMP2 USAR (Reference 26).The results of the [[ ]] LOCA containment dynamic loads evaluation demonstrate that existing vent clearing jet loads, pool swell, CO, and chugging load definitions remainbounding for operation in the MELLLA+ operating domain. Therefore, the LOCA containment dynamic loads are not affected by the MELLLA+ operating domain expansion. 4.1.2.2 Subcompartment Pressurization Reduced FW temperature increases the subcooling in the FW and reactor recirculation lines,which increases the break flow rates for liquid line breaks. The current subcompartment pressurization loads evaluations consider the current licensed operating domain, which includesan operational band of-20'F (with a minimum FW temperature of 420.5°F at rated power). Thisanalysis concludes that break flow rates for liquid line breaks such as FW and recirculation linebreaks for the MELLLA+ expanded operating domain are bounded by the break flow rates forthe current licensed operating domain. This operation band remains valid for the MELLLA+operating domain.4.1.2.2.1 Annulus Pressurization Load Evaluation The results from the updated dynamic analyses, including effects from both EPU and the non-conservative assumptions, were compared against those used as input to the component structural analyses of record. The effect of the increase in AP loads on the total component stresses is reduced when the AP loads are combined with the SSE seismic loads by the squareroot of the sum of the squares in the faulted load combination. The SSE seismic loads in the loadcombination are not affected by EPU. The effect of MELLLA+ on the EPU AP load SC 09-01evaluation has determined that the ARS remains conservative for the rated power MELLLA+.The off-rated SC 09-01 methods show minor changes in the sub compartment pressurization related to the updated methods associated with SC 09-01 when combined with the jet reactionloads and jet impingement loads using conservative assumptions. The minor changes in ARSfrequency when combined in the faulted load combination with seismic show that theconclusions reached for the EPU assessment remain bounding with a few locations showingminor increases. The results of these evaluations show that all reactor vessel and internals, andassociated vessel attachments and supports remain within design basis faulted allowable limits.Because the MELLLA+ operating domain AP subcompartment pressurization are bound by thecurrent licensed operating domain, no further evaluation of this topic is required. The evaluation of the NMP2-specific AP subcompartment pressurization is determined to beacceptable for NMP2.4-3 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)4.1.2.2.2 Drywell Head Subcompartment Pressurization Evaluation The pressure loading on the DW head refueling bulkhead plate to a postulated break in the RCIChead spray line in the DW head subcompartment is not affected by MELLLA+. The pressureand temperature/enthalpy for the RCIC is either not affected or may be slightly reduced in valuecompared to EPU. The postulated RSLB in the DW affects the upward pressure loading on thebulkhead plate and remains bounded by the EPU evaluation as the fluid enthalpy at the breaklocation is not significantly affected (less than 1%), while the break location pressure is the sameas at CLTP. Therefore, the DW head refueling bulkhead plate design margins is unchanged. Because the MELLLA+ operating domain DW head subcompartment pressurization is bound bythe current licensed operating domain, no further evaluation of this topic is required. The evaluation of the NMP2-specific DW head subcompartment pressurization is determined tobe acceptable for NMP2.4.1.2.2.3 Biological Shield Wall Subcompartment Pressurization Evaluation The differential pressure loading on the biological shield wall (BSW) is not significantly affectedby MELLLA+. The pressure and temperature/enthalpy for the high energy systems penetrating the BSW (recirculation, LPCS, HPCS, feedwater) are either not affected or may be slightlyreduced in value compared to EPU. The peak BSW differential pressure load resulting from thelimiting recirculation pump discharge line break at CLTP and MELLLA+ conditions remainsbounded by the EPU evaluations and remains below the BSW design differential pressure. Inaddition, the EPU AP load SC 09-01 evaluation for the BSW remains conservative whenconsidering MELLLA+ and the off-rated operating conditions. Because the MELLLA+ operating domain BSW subcompartment pressurization is bound by thecurrent licensed operating domain, no further evaluation of this topic is required. The evaluation of the NMP2-specific BSW subcompartment pressurization is determined to beacceptable for NMP2.4.1.2.3 SRV Piping -Containment Dynamic Loadsbecause the sensible and decay heat do not change in the MELLLA+ operating domain, andbecause the SRV setpoints do not change, the SRV loads do not change. Therefore, no furtherevaluation of this topic is required. [[ ]] the sensible and decay heat do notchange as a result of MELLLA+ operating domain expansion. This response is discussed inSection 1.2.3. Also, there is no change to the NMP2 SRV setpoints as a result of MELLLA+operating domain expansion. This topic is discussed in Section 3.1.2. Therefore, there is nochange to the NMP2 SRV loads. No further evaluation of this topic is required. 4-4 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)4.1.2.4 SRV -Containment Dynamic LoadsThe basis for the M+LTR (Reference

1) generic SRV containment load disposition wasconfirmed to be applicable to NMP2.Section 4.1 of the M+LTR (Reference
1) provides the following generic disposition for the effectof MELLLA+ on long-term suppression pool temperature response and SRV loads;4.1.3 Containment Isolation

]] evaluation is required todemonstrate the adequacy of the containment isolation system.]] Therefore, no containment isolation system evaluations are required forNMP2.[[4.1.4 Generic Letter 89-10Topic M+LTR Disposition NMP2 ResultGeneric Letter 89-10 Generic Letter 89-16Generic Letter 95-07Generic Letter 96-06 ]] evaluation toevaluate changes to the GL 89-10 program is required. 4-5 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)]] Sections 6.6 and 10.1 confirm that other parameters with the potential toaffect the capability of safety-related MOVs, such as the ambient temperature

profile, arebounded by the current design basis. Therefore, a separate plant-specific GL 89-10 MOVprogram evaluation is not required.

4.1.5 Generic Letter 89-16GL 89-16 (Reference

28) is not applicable to NMP2.4.1.6 Generic Letter 95-07evaluation of the GL 95-07 program is required.

]] Therefore, no GL 95-07 evaluation is required. 4.1.7 Generic Letter 96-06[[Ievaluation of the GL 96-06 program is required. [[]] Therefore, no GL 96-06 evaluation is required. O[[4.2 EMERGENCY CORE COOLING SYSTEMSThe ECCS includes HPCS, the LPCS system, the LPCI mode of the RHR system, and the ADS.The topics addressed in this evaluation are:4-6 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Topic M+LTR Disposition NMP2 ResultHigh Pressure Coolant Injection N/A to NMP2 N/A to NMP2High Pressure Core SprayLow Pressure Core SprayLow Pressure Coolant Injection Mode of the Residual HeatRemoval SystemAutomatic Depressurization SystemEmergency Core Cooling System Net Positive Suction Head4.2.1 High Pressure Coolant Injection The HPCI system is not applicable to NMP2.4.2.2 High Pressure Core Spray[[ ]] the HPCSsystem is designed to spray water into the reactor vessel over a wide range of operating pressures. In the event of a small break LOCA that does not immediately depressurize thereactor vessel, the HPCS system provides reactor vessel coolant inventory makeup to maintainreactor water level and help depressurize the reactor vessel. This system also provides spraycooling for long-term core cooling after a LOCA. In addition, the HPCS system serves as abackup to the RCIC system to provide makeup water in the event of a LOFW flow transient. Forthe MELLLA+ operating domain expansion, there is no change in the normal reactor operating

pressure, decay heat, and the SRV setpoints.

[[no further evaluation of the HPCSsystem is required. [[ ]] there is no change to the normal reactor pressure asa result of MELLLA+ operating domain expansion. The numerical values showing no increases in reactor operating pressure are presented in Table 1-2. The sensible and decay heat do notchange as a result of MELLLA+ operating domain expansion. This response is discussed inSection 1.2.3. Also, there is no change to the NMP2 SRV setpoints as a result of MELLLA+operating domain expansion. This topic is discussed in Section 3.1.2. [[]] and no further evaluation of the HPCS system is required. 4-7 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)4.2.3 Low Pressure Core Spray[I ]] the LPCS systemis automatically initiated in the event of a LOCA. The primary purpose of the LPCS system is toprovide reactor coolant makeup for a large break LOCA and for any small break LOCA after thereactor vessel has depressurized. It also provides spray cooling for long-term core cooling in theevent of a LOCA. [[]] no further evaluation of the LPCS system for MELLLA+.]] there is no change to the reactor pressure as a resultof MELLLA+ operating domain expansion. The numerical values showing no increases inreactor operating pressure are presented in Table 1-2. [[]] and no further evaluation of the LPCS system is required. [[4.2.4 Low Pressure Coolant Injection [[ ]] the LPCI mode of the RHRsystem is automatically initiated in the event of a LOCA. The primary purpose of the LPCImode is to provide reactor coolant makeup for a large break LOCA and for any small breakLOCA after the reactor vessel has depressurized. [[]] no further evaluation ofLPCI for MELLLA+.[[ ]] there is no change to the reactor pressure as a resultof MELLLA+ operating domain expansion. The numerical values showing no increases inreactor operating pressure are presented in Table 1-2. [[]) and no further evaluation of the LPCI mode is required. In the event of a design basis4-8 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Appendix R event discussed in Section 6.7, the LPCI mode of RHR injects water into the reactorvessel to restore inventory and maintain core cooling following vessel depressurization. 4.2.5 Automatic Depressurization SystemR the ADS uses SRVs toreduce the reactor pressure following a small break LOCA, when it is assumed that the highpressure systems have failed. This allows the LPCS and LPCI systems to inject coolant into thereactor vessel. [[]] no further evaluation of the ADS isrequired. [[]] and no further evaluation of the ADS is required. Er4.2.6 ECCS Net Positive Suction HeadEr ]] theMELLLA+ operating domain expansion does not result in an increase in the heat addition to thesuppression pool following a LOCA, station blackout (SBO), or Appendix R event. [[]] There are nophysical changes in the piping or system arrangement. There is no change in the operator actionsto throttle the RHR and CS pumps.Er ]] there is no increase in the heat addition to thesuppression pool following a LOCA, SBO, or Appendix R event (see Sections 4.1.2, 9.3.2, and6.7, respectively). For NMP2, the most limiting case for ECCS NPSH is confirmed to occur atthe long-term suppression pool temperature during a LOCA, [[]] There are also no changes in NMP2 ECCS pipingor system arrangement. There is no change in the operator actions to throttle the RHR and CSpumps. Therefore, all criteria related E[ ]] of ECCS-NPSH are met,and no further evaluation is required. The suppression pool temperature following an ATWS is bounded by EPU.4-9 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)M+LTR SER Limitation and Condition 12.23.9 requires that plant-specific applications mustreview the safety system specifications to ensure that all of the assumptions used for the ATWSSE indeed apply to their plant-specific conditions including providing information on crucialsystems like HPCI and physical limitations like NPSH and maximum vessel pressure that RCICand HPCI can inject. NMP2 does not have a HPCI system. In response to an NRC RAI for theEPU LAR, NMP2 performed NPSH evaluation for ECCS pumps for variety of scenarios including DBA-LOCA and ATWS. The NPSH evaluation did not credit containment accidentoverpressure (Reference 31). As discussed above, MELLLA+ suppression pool temperature forDBA-LOCA is bounded by EPU. In addition, MELLLA+ ATWS suppression pool temperature is also bounded by EPU ATWS as shown in Table 9-4. Therefore, reduction in MELLLA+containment pressure has no effect on the ECCS pump operability in regard to NPSH.Therefore, NMP2 complies with M+LTR SER Limitation and Condition 12.23.9 related toNPSH and ECCS pump operability. The EPU analysis of ECCS NPSH remains bounding for MELLLA+. The NRC reviewed theECCS NPSH requirements as part of the EPU LAR, and stated in the NRC's SER for the NMP2EPU LAR dated December 22, 2011 (Reference

14) that the NMP2 ECCS NPSH meets theguidance in RG 1.1 (Reference 32), does not credit containment accident pressure to ensureadequate NPSH, and meets NRC staff guidance on NPSH uncertainty and operation in maximumerosion zone.4.3 EMERGENCY CORE COOLING SYSTEM PERFORMANCE The NMP2 ECCS is designed to provide protection against postulated LOCAs caused byruptures in the primary system piping. The ECCS performance characteristics do not change forthe MELLLA+ operating domain expansion.

The topics addressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultLarge Break Peak Clad Temperature Small Break Peak Clad Temperature Local Cladding Oxidation Core-Wide Metal Water ReactionCoolable GeometryLong-Term CoolingFlow Mismatch LimitsThese topics are described in Sections 4.3.2 through 4.3.8.4.3.1 Break Spectrum Response and Limiting Single Failure]] The break spectrum response is determined by the ECCS network design and iscommon to all BWRs. SAFER evaluation experience shows that the basic break spectrum4-10 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)response is not affected by changes in CF (Reference 33). [[M+LTR SER Limitation and Condition 12.14 requires that for plants that will implement MELLLA+, a sufficient number of small break sizes shall be analyzed at the rated EPU powerlevel to ensure that the peak peak cladding temperature (PCT) break size is identified. [[]]The factors influencing the selection of the limiting single failure for NMP2 are [[]] The trends discussed in the M+LTR regarding the first and second clad temperature peaks of large breaks are applicable to NMP2. [[]]The factors influencing the selection of the small break limiting single failure for NMP2 are4.3.2 Large Break Peak Clad Temperature The effect of MELLLA+ operating domain expansion on the NMP2 LOCA performance issimilar to that observed in the current licensed operating domain, which includes the MELLLAoperating domain low CF region. The PCT response following a large recirculation line breakhas two peaks. The first peak is determined by the boiling transition during CF coastdown earlyin the event. The second peak is determined by the core uncovery and reflooding. MELLLA+ operating domain expansion has two effects on the boiling transition and first peakPCT. First, the reduced CF causes the boiling transition to occur earlier and lower in the bundle.Second, the reduced CF causes the initial subcooling in the downcomer to be higher so that thebreak flow is greater in the early phase of the LOCA event. For a given power level, the earlyboiling transition times (boiling transitions that occur before jet pump uncovery) for NMP2occur earlier in the event and penetrate lower in the fuel bundle as the CF is reduced, but theeffect of the early boiling transition on the LOCA PCT depends on the particular conditions. Effect of MELLLA+ at Rated PowerThe PCT results are shown in the table at the end of this section. [[4-11 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Effect of MELLLA+ at Less Than Rated PowerM+LTR SER Limitation and Condition

12. 1O.a requires the M+SAR to provide a discussion onthe power/flow combination scoping calculations that were performed to identify the limitingstatepoints in terms of DBA-LOCA PCT response for the operation within the MELLLA+boundary.

As required by this limitation, [[]] The PCT results summarized below show that there are no unusualtrends in PCT in the MELLLA+ region and that there is margin to the 2,200'F PCT limit.Effect of Axial Power ShaveAs required by M+LTR SER Limitation and Condition 12.11 (Reference

1) and Methods LTRSER Limitation and Condition 9.7 (Reference
3) for MELLLA+ applications, the small and largebreak ECCS-LOCA analyses shall include top-peaked and mid-peaked power shape inestablishing the MAPLHGR and determining the PCT. This limitation is applicable to both thelicensing basis PCT and the upper bound PCT. The plant-specific applications should report thelimiting small and large break licensing basis and upper bound PCTs. [[4-12 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION

-CLASS I (PUBLIC)Power/Flow' Nominal PCT (OF) 2 Appendix K PCT (OF) 21st Peak 2nd Peak 1st Peak 2nd PeakNotes: 1 Power level shown is percent at EPU condition. Flow level shown is percent of RCF.2 Results are for GE14 DBA large break.4.3.3 Small Break Peak Clad Temperature I[[Effect of MELLLA+ at Rated PowerThe PCT results are shown in the table at the end of this section. 1M+LTR SER Limitation and Condition 12.13 requires that the MELLLA+ plant-specific SARinclude calculations for the limiting small break at rated power/RCF and rated power/MELLLA+

boundary, if the small break PCT at rated power/RCF is within [[ ]] of the limitingAppendix K PCT. For NMP2, the small break PCT is limiting.

Therefore, small break PCTcalculations are performed for MELLLA+ flow, and the PCT results are shown in the table at theend of this section.Effect of MELLLA+ at Less Than Rated PowerM+LTR SER Limitation and Condition 12.1O.b requires that the M+SAR provide a justification as to why the transition statepoint ECCS-LOCA response bounds the 55% CF statepoint. ]] The PCT results4-13 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)summarized below show that there are no unusual trends in PCT in the MELLLA+ region andthat there is margin to the 2,200'F PCT limit.Effect of Axial Power ShapeAs required by M+LTR SER Limitation and Condition 12.11 and Methods LTR SER Limitation and Condition 9.7 for MELLLA+ applications, the small and large break ECCS-LOCA analyseshave included top-peaked and mid-peaked power shapes in establishing the MAPLHGR anddetermining the PCT. This limitation is applicable to both the licensing basis PCT and the upperbound PCT. The plant-specific applications have confirmed that the limiting small and largebreak with [[]]Small Break Licensing Basis PCTReference 34 provides justification for the elimination of the 1,600'F upper bound PCT limit andgeneric justification that the licensing basis PCT will be conservative with respect to the upperbound PCT. The NRC SER in Reference 34 accepted this position by noting that, because plant-specific upper bound PCT calculations have been performed for all plants, other means may beused to demonstrate compliance with the original SER limitations. These other means areacceptable provided there are no significant changes to a plant's configuration that wouldinvalidate the existing upper bound PCT calculations. The changes in magnitude of the PCT dueto MELLLA+ demonstrate that this plant configuration change does not invalidate the existingupper bound PCT calculations. M+LTR SER Limitations and Conditions 12.12.a and 12.12.b and Methods LTR SER Limitation and Condition 9.8 also require that the ECCS-LOCA evaluation be performed for all statepoints in the upper boundary of the expanded operating domains. [[]] The calculated GEl4 licensing basis PCT is 1,580'F, based on the limiting casescenario. [[4-14 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Power/Flow' Nominal PCT (*F)2 Appendix K PCT (OF)2Notes:Power level shown is percent at EPU power level. Flow level shown is percent of RCF.2 Results are for GEl4 limiting small break.4.3.4 Local Cladding Oxidation Er]] Sections 4.3.2 and 4.3.3 that determine the effect on the PCT. [[]] and no further evaluation of this topic is required. Er ]] for NMP2, Sections 4.3.2 and4.3.3 show acceptable PCT results that meet the 2,200'F limit. [[]] and no furtherevaluation of this topic is required. 4.3.5 Core-Wide Metal Water Reaction Sections 4.3.2 and 4.3.3 that determine the effect on the PCT. [[]] and no further evaluation of this topic is required. ]] for NMP2, Sections 4.3.2 and4.3.3 show acceptable PCT results that meet the 2,200'F limit. [[]] and no furtherevaluation of this topic is required. 4-15 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)4.3.6 Coolable Geometry]] NMP2's compliance with thecoolable geometry acceptance criteria was generically demonstrated as a GEH BWR 4.3.7 Long-Term Cooling NMP2's compliance with the long-term cooling acceptance criteria was generically demonstrated as a GEH BWR [[4.3.8 Flow Mismatch Limitslimits have been placed on recirculation drive flow mismatch over a range of CFs. For mostplants, the limits on flow mismatch are more relaxed at lower CF rates. The drive flowmismatch affects the CF coastdown following the break. The effect of the drive flow mismatchon the LOCA evaluation is similar to a small change in the initial CF. [[]] the discussion and trends in theM+LTR are applicable to NMP2. [[4-16 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)]]4.4 MAIN CONTROL ROOM ATMOSPHERE CONTROL SYSTEMThe topics addressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultIodine Intake[[ ]] theMELLLA+ operating domain expansion does not result in a change in the source terms or therelease rates (Section 8.0). [[]] Provided this criterion ismet, no further evaluation of the Main Control Room (MCR) atmosphere control system isrequired. [[ ]] there is no change in the NMP2source term or release rates as a result of MELLLA+ operating domain expansion. This topic isdiscussed in Section 8.0. [[]] No further evaluation ofthe MCR atmosphere control system is required. I[[4.5 STANDBY GAS TREATMENT SYSTEMThe topics addressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultFlow CapacityIodine Removal Capability 4.5.1 Flow Capacity[ ]]theSGTS is designed to maintain secondary containment at a negative pressure and to filter theexhaust air for removal of fission products potentially present during abnormal conditions. Bylimiting the release of airborne particulates and halogens, the SGTS limits off-site dose following a postulated DBA. [[]] and no furtherevaluation of the SGTS flow is required. [[ ]] the design flow capacity of theNMP2 SGTS was selected to maintain the secondary containment at the required negativepressure to minimize the potential for exfiltration of air from the Reactor Building. [[4-17 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)]] and no further evaluation is required. 4.5.2 Iodine Removal Capability [[]] the SGTS is designed to maintain secondary containment at a negative pressure and tofilter the exhaust air for removal of fission products potentially present during abnormalconditions. By limiting the release of airborne particulates and halogens, the SGTS limits off-site dose following a postulated DBA. [[]] the core fission product inventory isnot changed by the MELLLA+ operating domain expansion (Section 8.3), and coolant activitylevels are defined by TS and do not change, so no change occurs in the SGTS adsorber iodineloading, decay heat rates, or iodine removal efficiency. [[]] No further evaluation of this topic is required. 4.6 MAIN STEAM ISOLATION VALVE LEAKAGE CONTROL SYSTEMNMP2 does not use a MSIV leakage control system (LCS).4.7 POST-LOCA COMBUSTIBLE GAS CONTROL SYSTEMThe topics addressed in this evaluation are:M+LTRTopic NMP2 ResultPost-LOCA Combustible Gas Control ]]10 CFR 50.44 was revised in September 2003 and no longer defines a design basis LOCAhydrogen release. This new revision eliminates the requirements for hydrogen control systems tomitigate such a release. NMP2 has adopted the revised ruling per NMP2 license amendment Number 124, issued in April 2008, which relaxed the requirements for hydrogen and oxygenmonitoring. This amendment also eliminated the requirements for hydrogen recombiners for thepurpose of mitigating post-LOCA hydrogen

release, although NMP2 has chosen to leave therecombiners in place and remain functional.

NMPNS made commitments to maintain thehydrogen and oxygen monitoring systems capable of diagnosing beyond DBAs. MELLLA+operating domain expansion has no effect on the design of these systems or on the ability ofthese systems to perform their intended functions.

However, as this system is no longer required4-18 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION

-CLASS I (PUBLIC)to be maintained as a post-LOCA combustible gas control system, no further evaluation isnecessary relative to the MELLLA+ operating domain expansion. The generic disposition of thesystem (under the M+LTR) is no longer applicable. [[4-19 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)5.0 INSTRUMENTATION AND CONTROLThis section addresses the evaluations that are applicable to MELLLA+.5.1 NSSS MONITORING AND CONTROLChanges in process parameters resulting from the MELLLA+ operating domain expansion andtheir effects on instrument performance are evaluated in the following sections. The effect of theMELLLA+ operating domain expansion on the TS is addressed in Section 11.1 and the effect onthe allowable values (AVs) in Section 5.3. The topics addressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultAverage Power Range, Intermediate Range,and Source Range MonitorsLocal Power Range MonitorsRod Block MonitorRod Worth Minimizer Traversing Incore Probes5.1.1 Average Power Range, Intermediate Range, and Source Range MonitorsI[[]] the APRM output signals are calibrated to read 100% at the CLTP.]] Using normal plant surveillance procedures, the IRMs may be adjusted to ensure adequate overlap with the SRMs and APRMs.Therefore, no further evaluation of the APRMs, IRMs, or SRMs is required for MELLLA+.[[ ]] there is no change in NMP2 corepower as a result of MELLLA+ operating domain expansion. [[]] TheAPRMs, IRMs, and SRMs are installed at NMP2 in accordance with the requirements established by the GEH design specifications. NMP2 uses normal plant procedures to adjust theIRMs to ensure adequate overlap with the SRMs and APRMs. Therefore, no further evaluation is required. 5.1.2 Local Power Range Monitors[[ ]] there is nochange in the neutron flux experienced by the LPRMs resulting from the MELLLA+ operating domain expansion. [[5-1 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)]] No further evaluation of these topics is requiredfor MELLLA+.[[ ]] there is no change in the neutronflux experienced by the NMP2 LPRMs resulting from the MELLLA+ operating domainexpansion. Analysis was performed to confirm that bypass voiding at the D Level LPRM doesnot exceed 5%. Therefore, [[]] The LPRMs are installed at NMP2 in accordance with therequirements established by the GEH design specifications. No further evaluation of these topicsis required for MELLLA+.1]]5.1.3 Rod Block MonitorsEr ]] the RBM usesLPRM instrumentation inputs that are combined and referenced to an APRM channel. [[]] and as described in Sections 5.1.1and 5.1.2, the [[]] No further evaluation ofthese topics is required for MELLLA+.Section 9.1.1 evaluates the adequacy of the generic RBM setpoints. Er5.1.4 Rod Worth Minimizer ]] the function of the RWM is to support the operator by enforcing rod patterns untilreactor power has reached appropriate levels. The RWM functions to limit the local power in thecore to control the effects of the postulated control rod drop accident (CRDA) at low power.E[ r]Therefore, no further evaluation is required. [[ ]] the NMP2 RWM supports theoperator by enforcing rod patterns until reactor power has reached appropriate levels.E[ r]Therefore, no further evaluation is required. E[5-2 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)5.1.5 Traversing Incore ProbesTo address the M+LTR SER Limitation and Condition 12.15, bypass voiding above the D-Level,an analysis was performed to identify the region on the MELLLA+ power/flow map that haspotentially unacceptable bypass voiding for the thermal traversing incore probes (TIPs) installed at NMP2. In the absence of bypass voiding greater than 5% no actions are required regarding theTIPs resulting from the MELLLA+ operating domain expansion. [[Analysis shows that there is a small region of the MELLLA+ power flow domain near point Min Figure 5-1 where the hot channel voiding at the TIP exit exceeds 5% thus requiring specificattention per Limitation and Condition 12.15. [[]] TIP operation and LPRM calibration in the remainder of the MELLLA+domain are not adversely affected by the void conditions in the bypass region. NMPNS controlroom operators and Reactor Engineers will be trained on this requirement and station procedures will be modified accordingly. [[ ]] there is no change in the neutronflux experienced by the NMP2 TIPs resulting from the MELLLA+ operating domain expansion. [[ ]] The TIPs are installed at NMP2 inaccordance with the requirements established by the GEH design specifications. No furtherevaluation of these topics is required for MELLLA+.[ 1]]5.2 BOP MONITORING AND CONTROLOperation of the plant in the MELLLA+ domain has no effect on the BOP systeminstrumentation and control devices. The topics addressed in this evaluation are:5-3 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Topic M+LTR Disposition NMP2 ResultPressure Control SystemTurbine Steam Bypass System (Nomial Operation) Turbine Steam Bypass System (Safety Analysis) Feedwater Control System (Normal Operation) Feedwater Control System (Safety Analysis) Leak Detection System _]5.2.1 Pressure Control System]] Therefore, no further evaluation of this system isrequired as a result of MELLLA+.[[ ]] for NMP2, there are no increases in reactor operating

pressure, MS or FW flow rates. The numerical values showing no increases in reactor operating
pressure, MS or FW flow rates are presented in Table 1-2. The systemdynamic characteristics of the NMP2 pressure control system are not changed.

[[]] Therefore, no further evaluation of thissystem is required as a result of MELLLA+.5.2.2 Turbine Steam Bypass System (Normal Operation) ]] Therefore, no further evaluation ofthis system is required as a result of MELLLA+.[[ ]] for NMP2, there are no increases in reactor operating

pressure, MS or FW flow rates. The numerical values showing no increases in reactor operating
pressure, MS or FW flow rates are presented in Table 1-2. The systemdynamic characteristics of the NMP2 turbine steam bypass system under normal operation arenot changed.

[[]] Therefore, no further evaluation of this system is required as a result of MELLLA+.5-4 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)5.2.3 Turbine Steam Bypass System (Safety Analysis) ]] Therefore, no further evaluation ofthis system is required as a result of MELLLA+.[R ]] for NMP2, there are no increases in reactor operating

pressure, MS or FW flow rates. The numerical values showing no increases in reactor operating
pressure, MS or FW flow rates are presented in Table 1-2. The systemdynamic characteristics of the NMP2 turbine steam bypass system in safety analysis conditions are not changed.

1Therefore, no further evaluation of this system is required as a result of MELLLA+.[[I5.2.4 Feedwater Control System (Normal Operation) I Therefore, no further evaluation of this systemis required as a result of MELLLA+.R]] for NMP2, there are no increases in reactor operating

pressure, MS or FW flow rates. The numerical values showing no increases in reactor operating
pressure, MS or FW flow rates are presented in Table 1-2. The systemdynamic characteristics of the NMP2 FW control system under normal operation are notchanged.

[[]] Therefore, no furtherevaluation of this system is required as a result of MELLLA+.[[I5.2.5 Feedwater Control System (Safety Analysis) ]] Therefore, no further evaluation of this systemis required as a result of MELLLA+.[[ ]] for NMP2, there are no increases in reactor operating

pressure, MS or FW flow rates. The numerical values showing no increases in reactor operating
pressure, MS or FW flow rates are presented in Table 1-2. The system5-5 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION

-CLASS I (PUBLIC)dynamic characteristics of the NMP2 FW control system in safety analysis conditions are notchanged. [[]] Therefore, no furtherevaluation of this system is required as a result of MELLLA+.5.2.6 Leak Detection System Therefore, no further evaluation of this system isrequired as a result of MELLLA+.[[ ]] for NMP2, there are no increases in reactor operating

pressure, MS or FW flow rates. In addition, RWCU, RHR, HPCS, andRCIC pressures, temperatures, and flows are unchanged.

The numerical values showing noincreases in reactor operating

pressure, MS or FW flow rates are presented in Table 1-2. Inaddition, as discussed in Section 4.1.2, suppression pool time history response temperatures inthe MELLLA+ operating domain are bounded by the EPU results.

Therefore, the systemdynamic characteristics of the NMP2 leak detection system are not changed. [[]] Therefore, no further evaluation of thissystem is required as a result of MELLLA+.5.3 TECHNICAL SPECIFICATION INSTRUMENT SETPOINTS The TS instrument AVs and the nominal trip setpoints (NTSPs) are those sensed variables whichinitiate protective actions and are generally associated with the safety analysis. Thedetermination of the AV and NTSP includes consideration of measurement uncertainty and arederived from the AL. Standard GEH setpoint methodology (Reference

35) is used to generatethe AV and NTSPs from the related ALs.The MELLLA+ operating domain expansion results in the development of two ALs.GEH typically uses the approved simplified process to determine the instrument AVs and NTSPsfor MELLLA+ applications.

The NRC staff has previously reviewed and accepted the simplified approach in the review of NEDC-33004P-A (Reference 7). Consistent with that approval, forNMP2 the following criteria are satisfied for using the simplified process:1. [[2. NRC approved GEH or plant-specific methodologies are used (Reference 35).5-6 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)3. [[However, complete setpoint calculations, using the setpoint methodology described inReference 35 have been performed for the APRM Flow Biased Scram and Rod Block for TLO,to better support NMP2 in implementing the guidance provided by Regulatory Issue Summary(RIS) 2006-17 (Reference

36) and Technical Specification Task Force (TSTF)-493 (Reference 37).The topics addressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultAPRM Flow-Biased Scram [[Rod Block Monitor5.3.1 APRM Flow-Biased ScramThe MELLLA+ APRM Flow Biased STP Scram AL line is established to [[]]The MELLLA+ APRM Flow Biased STP AL expressions are:ALM+ROD BLOCK = 0.61W + 60.1%, for the Rod Block, andALM+sCRAM

= 0.6 1W + 66.1%, for the Scram.SLO is not applicable to the MELLLA+ operating domain as discussed in Section 3.6.3.Therefore, the SLO setpoints are unchanged. The evaluation of APRM Flow Biased STP Scram setpoints is consistent with the methodsdescribed for [[ ]] this topic in the M+LTR. The APRM FlowBiased STP Scram setpoints for the NMP2 [[ are therefore acceptable. 5.3.2 Rod Block Monitor[]] the RBM setpoints are established to mitigate the rod withdrawal error (RWE) event during power operation. For plants with ARTS RBM systems, [[5-7 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)]] Therefore, no further evaluation of theRBM TS values is required as a result of MELLLA+.[[ ]] for NMP2, there is no change inreactor power level as a result of MELLLA+ operating domain expansion. NMP2 has an ARTSRBM system. [[Therefore, no further evaluation of the RBM TS values is required as a result of MELLLA+.5-8 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)I[Figure 5-1 NMP2 EPUIM+ Power/Flow Map with 5% Voiding at the TIP Exit Boundary5-9 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)6.0 ELECTRICAL POWER AND AUXILIARY SYSTEMSThis section addresses the evaluations that are applicable to MELLLA+. Because there is nochange in power output, most of the topics in this section are unaffected by the MELLLA+operating domain expansion. 6.1 AC POWERThe AC power supply includes both off-site and on-site power. The on-site power distribution system consists of transformers, buses, and switchgear. AC power to the distribution system isprovided from the transmission system or from on-site D/Gs. The topics addressed in thisevaluation are:Topic M+LTR Disposition NMP2 ResultAC Power (Normal or Degraded Voltage)]] there is no change in the thermal power from the reactor or the electrical output from the station that results from the MELLLA+ operating domain expansion. [[No further evaluation of the AC Power system is required. [[ ]] there is no change in the NMP2reactor thermal power or the electrical output from the station that results from the MELLLA+operating domain expansion. [[No further evaluation of the AC Power system is required. ]]6.2 DC POWERThe direct current (DC) power distribution system provides control and motive power for varioussystems/components within the plant. The topics addressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultDC PowerEr ]] theMELLLA+ operating domain expansion does not change system requirements for control or6-1 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)motive power loads. [[further evaluation of this topic is required. [R]] Therefore, no]] as a result of MELLLA+ operating domain expansion. The MELLLA+operating domain expansion does not change system requirements for control or motive powerloads. Therefore, no further evaluation of the DC Power system is required. 6.3 FUEL POOLThe topics addressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultFuel Pool Cooling:[ Crud Activity and Corrosion ProductsRadiation LevelsFuel Racks ]6.3.1 Fuel Pool Cooling_1MELLLA+ operating domain expansion does not increase the core power level. [[]] the]] No furtherevaluation of the fuel pool cooling systems are required for MELLLA+ operating domainexpansion. [[ ]] NMP2 reactor power level doesnot increase as a result of MELLLA+ operating domain expansion. [[]] No further evaluation of theNMP2 fuel pool cooling systems is required for MELLLA+ operating domain expansion. 1]6.3.2 Crud Activity and Corrosion Products]] No further evaluation of the crud and corrosion products in the spent fuelpools is required for MELLLA+ operating domain expansion. ]] Therefore, no further evaluation of the crud and corrosion products in the spentfuel pools is required for the NMP2 MELLLA+ operating domain expansion. 6-2 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)6.3.3 Radiation Levels[[]] No further evaluation of the radiation levels in the spent fuel pools isrequired for MELLLA+ operating domain expansion. [[Therefore, no further evaluation of the radiation levels in the spent fuel pools is required for theNMP2 MELLLA+ operating domain expansion. Er6.3.4 Fuel RacksEr ]] the MELLLA+operating domain expansion does not increase the core power level. [[]] No furtherevaluation of the fuel racks is required for MELLLA+ operating domain expansion. [[ ]] the MELLLA+ operating domainexpansion does not increase the NMP2 core power level. [[]] No furtherevaluation of the fuel racks is required for MELLLA+ operating domain expansion. 6.4 WATER SYSTEMSThe water systems are designed to provide a reliable supply of cooling water for normaloperation and DBA conditions. The topics addressed in this evaluation are:Topic M+LTR Disposition NMP2 Result]Water SystemsEE ]]theperformance of the safety-related service water system during and following the most limitingdesign basis event, the LOCA, is not affected by the MELLLA+ operating domain expansion. Er]] No furtherevaluation of water systems is required for MELLLA+.6-3 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)]] for NMP2, the MELLLA+operating domain expansion does not affect the performance of the safety-related emergency service water system or the RHR service water system during and following the most limitingdesign basis event, the LOCA, as discussed in Section 4.3. [[]] No further evaluation of the NMP2 water systems is required for MELLLA+operating domain expansion. 6.5 STANDBY LIQUID CONTROL SYSTEMThe SLS is an automatic or manually operated system that pumps a sodium pentaborate solutioninto the vessel to provide neutron absorption and achieve a subcritical reactor condition in thesituation where none of the control rods can be inserted. The topics addressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultShutdown Margin [[System HardwareATWS Requirements ]]6.5.1 Shutdown MarginI[[]]Anincrease in the reactor boron concentration may be achieved by increasing, either individually orcollectively, (1) the minimum solution volume, (2) the minimum specified solutionconcentration, or (3) the isotopic enrichment of the B10 in the stored neutron absorber solution. In order to account for reactivity variations between cycles, the USAR Section 9.3.5 limit forreactor coolant boron concentration has sufficient margin to accommodate most core designvariations. ]] Because no new fuel product linedesigns are introduced for MELLLA+ operating domain expansion, the USAR Section 9.3.5limit for minimum reactor coolant boron concentration of 780 ppm natural boron does notchange as a result of MELLLA+ operating domain expansion. NMP2 calculates SLS shutdownmargin as a part of the core reload analysis. Therefore, no further evaluation of SLS shutdownmargin is required for MELLLA+.6-4 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)6.5.2 System HardwareM+LTR describes that the SLS is typically designed for injection at a maximum reactor pressureequal to the upper analytical setpoint for the lowest group of SRVs operating in the relief mode.1]The NMP2 reactor operating pressure is unchanged by MELLLA+ operating domain expansion. The numerical values showing no increases in reactor operating pressure are presented inTable 1-2. As discussed in Section 3.1.2, there are no changes to the NMP2 SRV setpoints as aresult of MELLLA+ operating domain expansion. Because the reactor dome pressure and SRVsetpoints are unchanged for MELLLA+, the SLS process parameters do not change. Therefore, the capability of the SLS to perform its shutdown function is not affected by MELLLA+. [[]] Therefore, the NMP2 SLS remains capable of performing itsshutdown function. [[ Er6.5.3 ATWS Requirements As described in the M+LTR, the SLS ATWS performance is evaluated in Section 9.3.1 [[]] The representative MELLLA+ evaluation shows that the SLS maintains the capability to mitigate an ATWS andthat the current boron injection rate is sufficient relative to the peak suppression pooltemperature. The ATWS analysis in Section 9.3.1 also demonstrates that there is no increase inthe peak vessel dome pressure during the time the SLS is in operation. Er]] The pressure margin for the pump discharge relief valvesremains above the minimum value needed to ensure that the SLS relief valves remain closedduring system injection. Because NMP2 does not take credit for the operation of the SRVs in apower actuated relief mode during an ATWS, the peak reactor pressures for the loss of off-sitepower (LOOP) event would be the bounding ATWS event. The minimum reactor pressure, justprior to the time when SLS initiates, remains low enough to ensure SLS relief valve closure priorto the analyzed SLS initiation time in the event of an early initiation of the SLS during the initialATWS transient pressure response. Consequently, the current NMP2 SLS process parameters associated with the minimum boron injection rate do not need to change. Therefore, SLSoperation during an ATWS is not affected by the MELLLA+ operating domain expansion. 6-5 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)6.6 HEATING, VENTILATION AND AIR CONDITIONING The heating, ventilation, and air conditioning (HVAC) systems consist mainly of heating,cooling supply, exhaust and recirculation units in the Turbine Building, Reactor Building, DW,Control Building, and the Radwaste Building. The topics addressed in this evaluation are:Topic I M+LTR Disposition NMP2 ResultHeating, Ventilation, and Air Conditioning I]][]] the processtemperatures and heat load from motors and cables do not change due to MELLLA+ operating domain expansion. [[]] No further evaluations of the HVAC system are required for MELLLA+operating domain expansion. ]] for NMP2, HVAC systems, theprocess temperatures and heat load from motors and cables are bounded by the EPU processtemperatures and heat loads and as such are within the design of the HVAC equipment chosenfor worst case conditions. [[]] No further evaluations of the NMP2 HVAC systems arerequired for MELLLA+ operating domain expansion. 6.7 FIRE PROTECTION This section addresses the fire protection

program, fire suppression and detection
systems, andsafe shutdown system responses to postulated 10 CFR 50 Appendix R fire events. The topicsaddressed in this evaluation are:Topic M+LTR Disposition NNMP2 ResultFire Protection

[]] becausethe decay heat does not change for the MELLLA+ operating domain expansion, there are nochanges in vessel water level response, operator response time, PCT, and peak suppression pooltemperature and containment pressure. [[Provided the above criteria are met, no further evaluation of fire protection is required forMELLLA+ operating domain expansion. [[ ]] for NMP2, these parameters donot change as a result of MELLLA+ operating domain expansion. As discussed in Section 1.2.3,decay heat does not change as a result of MELLLA+ operating domain expansion. Reactor6-6 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)vessel water level response is unchanged by MELLLA+ operating domain expansion. Operatorresponse times are not affected by MELLLA+ because: [[]] The effect ofMELLLA+ operating domain expansion on PCTs is evaluated to be acceptable in Section 4.3.The effect of MELLLA+ operating domain expansion on peak suppression pool temperatures and containment pressure response are evaluated and concluded to be bounded by EPUconditions in Section 4.1. [[]] and no further evaluation of fire protection is required forMELLLA+ operating domain expansion. 6.8 OTHER SYSTEMS AFFECTEDThe topics addressed in this evaluation are other systems that may be affected by the MELLLA+operating domain expansion: Topic M+LTR Disposition NMP2 ResultOther Systemsthe systems typically found in a BWR power plant have been evaluated to establish thosesystems that are affected by the MELLLA+ operating domain expansion. Those systems that aresignificantly affected by the MELLLA+ operating domain expansion are addressed in this report.Other systems not addressed by this report are not significantly affected by the MELLLA+operating domain expansion. ]] the NMP2 systems evaluated [[were reviewed for MELLLA+ operating domainexpansion to ensure that all significantly affected systems were addressed. This topic confirmsthat those systems that are significantly affected by the MELLLA+ operating domain expansion are addressed in this report. Other systems not addressed by this report are not significantly affected by the MELLLA+ operating domain expansion. 6-7 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)7.0 POWER CONVERSION SYSTEMSThis section addresses the evaluations that are applicable to MELLLA+. Because the pressure, steam and FW flow rates, and FW fluid temperature ranges are not significantly changed by theoperating domain expansion, the power conversion systems are unaffected. 7.1 TURBINE-GENERATOR The turbine-generator converts the thermal energy in the steam into electrical energy. The topicsaddressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultTurbine-Generator [ ]]theMELLLA+ operating domain expansion does not change the pressure, thermal energy, and steamflow from the reactor.

Likewise, there is no change in the electrical output of the generator.

No further evaluation of this topic is required. [[ ]] there is no change in the reactorpower level as a result of MELLLA+ operating domain expansion. For NMP2, there are noincreases in reactor operating pressure or MS flow rates. The numerical values showing noincreases in reactor operating pressure and MS flow rates are presented in Table 1-2. Theelectrical output in the current licensed operating domain and in the MELLLA+ operating domain is approximately 1,368.9 MWe. Therefore, [[]] No furtherevaluation of this topic is required. 7.2 CONDENSER AND STEAM JET AIR EJECTORSThe condenser removes heat from the steam discharged from the turbine and provides liquid forthe condensate and FW systems. The steam jet air ejectors remove non-condensable gases fromthe condenser to improve thermal performance. The topics addressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultCondenser Steam Jet Air Ejectors]] the MELLLA+ operating domain expansion does not change the steam flowrate or power level. [[]] there is no change in the reactorpower level as a result of MELLLA+ operating domain expansion. For NMP2, there are no7-1 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)increases in reactor operating pressure or MS flow rates. The numerical values showing noincreases in reactor operating pressure and MS flow rates are presented in Table 1-2.[[]] MELLLA+ operating domainexpansion does not affect the condenser, and no further evaluation is required. MELLLA+ may increase the amount of moisture reaching the steam jet air ejectors motive steaminlet for short periods of time. The steam jet air ejectors would acceptably function because themaximum expected moisture at the steam jet air ejectors would be less than the typical industryguideline limit of 1 wt.% under the worst case moisture content at the inlet nozzles. The steamjet air ejectors will acceptably function in the MELLLA+ domain.[[]] The evaluation of the NMP2 steam jet air ejector is acceptable for MELLLA+ operation. 7.3 TURBINE STEAM BYPASSThe turbine steam bypass system provides a means of accommodating excess steam generated during normal plant maneuvers and transients. The topics addressed in this evaluation are:Topic M+LTR Disposition NMP2 Result]Turbine Steam Bypassthere is no change in the power level, pressure or steam flow for the MELLLA+ operating domain expansion. Therefore, MELLLA+ operating domain expansion does not affect theturbine steam bypass system, and no further evaluation is required. Er ]] there is no change in the reactorpower level as a result of the MELLLA+ operating domain expansion. For NMP2, there are noincreases in the reactor operating pressure or MS flow rates. The numerical values showing noincreases in the reactor operating pressure and MS flow rates are presented in Table 1-2.Therefore, MELLLA+ operating domain expansion does not affect the NMP2 turbine steambypass system, and no further evaluation is required. 7.4 FEEDWATER AND CONDENSATE SYSTEMSThe FW and condensate systems provide the source of makeup water to the reactor to supportnormal plant operation. The topics addressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultFeedwater and Condensate Systems[[]] there is no change in the FW pressure, temperature, or flow for the MELLLA+ operating 7-2 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)domain expansion. The performance requirements for the FW and condensate systems are notchanged by MELLLA+ operating domain expansion, and no further evaluation is required. [[ ]] there is no change in the NMP2FW pressure, temperature, and flow rates. Because FW flow is unchanged in the MELLLA+domain, system resistance and therefore operating pressures in the MELLLA+ operating domainare not changed. The numerical values showing no increases in FW temperature and flow ratesare presented in Table 1-2. Therefore, MELLLA+ operating domain expansion does not affectthe NMP2 FW and condensate

systems, and no further evaluation is required.

[[7-3 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)8.0 RADWASTE SYSTEMS AND RADIATION SOURCESThis section addresses the evaluations that are applicable to MELLLA+.8.1 LIQUID AND SOLID WASTE MANAGEMENT The Liquid radwaste system collects,

monitors, processes, stores and returns processed radioactive waste to the plant for reuse or discharge.

The topics addressed in this evaluation are:Topic M+LTR Disposition I NMP2 ResultCoolant Fission and Corrosion Product LevelsWaste Volumes8.1.1 Coolant Fission and Corrosion Product LevelsA discussion of the coolant activation products as well as fission and activated corrosion products levels in the coolant is presented in Section 8.4.8.1.2 Waste VolumesR]] becausethe power level, FW flow, and steam flow do not change for the MELLLA+ operating domainexpansion, the volume of liquid radwaste and the coolant concentrations of fission and corrosion products will be unchanged. The largest source of liquid and wet solid waste is from thebackwash of the condensate demineralizers. Although the volume of waste generated is notexpected to increase, potentially higher MCO in the reactor steam could result in slightly higherloading on the condensate demineralizers. Because the higher moisture content will occurinfrequently, the MELLLA+ operating domain expansion will not cause the condensate demineralizer backwash frequency to be changed significantly. The RWCU filter demineralizer backwash frequency is not affected, as discussed in Section 3.11. Therefore, the waste volumeswill not be affected by the MELLLA+ operating domain expansion, and no further evaluation ofthis topic is required. [[ ]] there is no change in the reactorpower level as a result of MELLLA+ operating domain expansion. For NMP2, there are noincreases in the MS or FW flow rates. The numerical values showing no increases in MS andFW flow rates are presented in Table 1-2. The NMP2 MCO will be monitored and controlled to< 0.25 wt.% within the analytical assumption of 0.35 wt.% used in the determination of post-shutdown radiation levels.[[I8.2 GASEOUS WASTE MANAGEMENT The primary function of the gaseous waste management (offgas) system is to process and controlthe release of gaseous radioactive effluents to the site environs so that the total radiation exposure of persons in off-site areas is as low as reasonably achievable (ALARA) and does notexceed applicable guidelines. The topics addressed in this evaluation are:8-1 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Topic M+LTR Disposition NMP2 ResultOff-Site Release RateRecombiner Performance 8.2.1 Off-Site Release Rate[[ ]]theradiological release rate is administratively controlled to remain within existing limits and is afunction of fuel cladding performance, main condenser air inleakage, charcoal adsorber inlet dewpoint, and charcoal adsorber temperature. []] No further evaluation of this topic is required. ]] the NMP2 radiological releaserate is administratively controlled to remain within existing release rate limits. In addition, noneof the applicable identified parameters are affected by MELLLA+ operating domain expansion. There is no change to the offgas system. Therefore, it can be concluded that the genericdiscussion in the M+LTR is applicable to NMP2. [[]], and no further evaluation isrequired. 8.2.2 Recombiner Performance Er Therefore, recombiner performance is unaffected by the MELLLA+ operating domain expansion, and no further evaluation is required. Er ]] the NMP2 radiolytic gas flow rate,the catalytic recombiner temperature, and the offgas condenser heat load, as well as components downstream of the offgas condenser does not change as a result of MELLLA+ operating domainexpansion. Therefore, the NMP2 recombiner performance is unaffected by the MELLLA+operating domain expansion, and no further evaluation is required. Er]]8-2 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)8.3 RADIATION SOURCES IN THE REACTOR COREDuring power operation, the radiation sources in the core are directly related to the fission rate.These sources include radiation from the fission process, accumulated fission products, andneutron activation reactions. The topics addressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultPost-Operational Radiation Sources forRadiological and Shielding Analysis]] the post-operation radiation sources inthe core are primarily the result of accumulated fission products. [[]] Therefore, no further evaluation ofradiation sources in the reactor core is required. [[ ]] the reactor power does notincrease as a result of MELLLA+ operating domain expansion. NMP2 core average exposure isNo further evaluation of radiation sources in the reactor core is required. 8.4 RADIATION SOURCES IN REACTOR COOLANTRadiation sources in the reactor coolant include activation

products, activation corrosion
products, and fission products.

The topics addressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultCoolant Activation Products [[Fission and Activated Corrosion Products8.4.1 Coolant Activation Products[[]] during reactor operation, the coolant passing through the core region becomesradioactive as a result of nuclear reactions. The coolant activation process is the dominantsource resulting in the production of short-lived radionuclides of N-16 and other activation products. These coolant activation products are the primary source of radiation in the turbinesduring operation. The M+LTR states that if [[]] no further evaluation of this topic is required. ]] the reactor power does notincrease as a result of MELLLA+ operating domain expansion. The NMP2 steam flow rate does8-3 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)not change as a result of MELLLA+ operating domain expansion. Numerical valuesdemonstrating that the MS flow does not increase are provided in Table 1-2. [[]] No further evaluation of this topic is required. [[I8.4.2 Fission and Activated Corrosion ProductsThe reactor coolant contains fission products and activated corrosion products. For theMELLLA+ operating domain, there is no change in the FW flow, steam flow, or power.However, [[For NMP2, reactor power does not change as a result of the MELLLA+ operating domainexpansion. The NMP2 MS and FW flow rates do not change as a result of the MELLLA+operating domain expansion. Numerical values demonstrating that the MS and FW flow rates donot increase are provided in Table 1-2. Therefore, the MELLLA+ operating domain expansion does not affect the total activity concentration in the reactor coolant.Steam separator and dryer performance for MELLLA+ operation is discussed in Section 3.3.3.The moisture content of the MS leaving the vessel is assumed to increase up to 0.35 wt.% attimes while operating near the minimum CF in the MELLLA+ operating domain. Thedistribution of the fission and activated corrosion product activity between the reactor water andsteam is affected by the increased moisture content. With increased MCO, additional activity iscarried over from the reactor water with the steam. For NMP2, certain individual activation product concentrations were observed to exceed design basis levels at 0.35 wt.% moisturecontent.

However, total activation product activity was below 30% of the total design basisactivation product activity for water and below 95% of the total design basis activation productactivity for steam. There are no individual design basis requirements for individual activation products.

No fission product concentrations exceeded the design basis.8.5 RADIATION LEVELSRadiation levels during operation are derived from coolant sources. The topics addressed in thisevaluation are:Topic M+LTR Disposition NMP2 ResultNormal Operational Radiation Levels [_Post-Shutdown Radiation LevelsPost-Accident Radiation Levels ]]8-4 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)8.5.1 Normal Operational Radiation LevelsThe M+LTR describes that plant radiation levels for normal and post-shutdown operation aredirectly dependent upon radiation levels and radionuclide species in the reactor coolant (steamand water) except where the core is directly involved. [[]]For NMP2, reactor power does not change as a result of the MELLLA+ operating domainexpansion. The NMP2 MS flow rate does not change as a result of the MELLLA+ operating domain expansion. Numerical values demonstrating the MS flow rate does not increase areprovided in Table 1-2. Because there is no change in power or steam flow rate for theMELLLA+ expanded operating domain, the radiation levels from the coolant activation productsdo not vary significantly. As discussed in Section 8.4, the moisture content of the MS leavingthe vessel may increase at certain times while operating in the MELLLA+ operating domain.However, the NMP2 MCO will be monitored and controlled to < 0.25 wt.% within the analytical assumption of 0.35 wt.% used in the determination of normal operation radiation levels. Theoverall radiological effect of the increased moisture content is a function of the plant waterradiochemistry and the levels of activated corrosion products maintained. NMP2 maintains appropriate health physics and ALARA controls to address any increase in the normal operation levels.8.5.2 Post-Shutdown Radiation LevelsThe M+LTR describes that plant radiation levels for normal and post-shutdown operation aredirectly dependent upon radiation levels and radionuclide species in the reactor coolant (steamand water) except where the core is directly involved. [[]]For NMP2, reactor power does not change as a result of the MELLLA+ operating domainexpansion. The NMP2 MS flow rate does not change as a result of the MELLLA+ operating domain expansion. Numerical values demonstrating the MS flow rate does not increase areprovided in Table 1-2. The shutdown radiation levels are dominated by the accumulated contamination of some fission and activated corrosion products. As discussed in Section 8.4, themoisture content of the MS leaving the vessel may increase at certain times while operating inthe MELLLA+ operating domain. However, the NMP2 MCO will be monitored and controlled to < 0.25 wt.% within the analytical assumption of 0.35 wt.% used in the determination ofpost-shutdown radiation levels. The overall radiological effect of the increased moisture contentis a function of the plant water radiochemistry and the levels of activated corrosion productsmaintained. NMP2 maintains appropriate health physics and ALARA controls to address anyincrease in the shutdown radiation levels.8-5 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)8.5.3 Post-Accident Radiation LevelsThe M+LTR describes that the post-accident radiation levels depend primarily upon the coreinventory of fission products and TS levels of radionuclides in the coolant, neither of which isaffected by MELLLA+. [[]] Section 9.2 discusses DBA radiological consequences. 8.6 NORMAL OPERATION OFF-SITE DOSESThe primary source of normal operation off-site doses is: (1) airborne releases from the offgassystem; and (2) gamma shine from the plant turbines. The topics addressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultPlant Gaseous Emissions [[Gamma Shine from the Turbine8.6.1 Plant Gaseous Emissions for the MELLLA+ operating domain expansion, there is no change in the core power and thesteam flow rate. [[ ]] Nofurther evaluation of plant gaseous emissions is required. Er ]] the reactor power does not changeas a result of the MELLLA+ operating domain expansion. The NMP2 steam flow rate does notchange as a result of the MELLLA+ operating domain expansion. Numerical valuesdemonstrating that the MS flow does not increase are provided in Table 1-2. [[]] Therefore, no further evaluation of plant gaseous emissions is required. 8.6.2 Gamma Shine from the Turbine]] Provided these conditions are met, no further evaluation of gamma shine fromthe turbine is required. [[ ]] and as discussed in Section 3.2.1,the change in flux as a result of the MELLLA+ operating domain expansion is insignificant. TheNMP2 steam flow rate does not change as a result of the MELLLA+ operating domainexpansion. Numerical values demonstrating the MS flow does not increase are provided in8-6 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Table 1-2. [[8-7 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)9.0 REACTOR SAFETY PERFORMANCE EVALUATIONS This section addresses the evaluations that are applicable to MELLLA+.9.1 ANTICIPATED OPERATIONAL OCCURRENCES The NMP2 USAR defines the licensing basis AOOs. Table 9-1 of the M+LTR provides anassessment of the effect of the MELLLA+ operating domain expansion on each of theReference 4 limiting AOO events and key non-limiting events. Table 9-1 of the M+LTRincludes fuel thermal margin, overpressure, and loss of water level events. The overpressure protection analysis events are addressed in Section 3.1. The topics addressed in this evaluation are as follows:Topic M+LTR Disposition NMP2 ResultFuel Thermal Margin Events Power and Flow Dependent LimitsNon-Limiting Events 9.1.1 Fuel Thermal Margin Eventsi The limiting thermal margin events definedin Reference 4 include:* Generator Load Rejection Without Bypass (LRNBP) or Turbine Trip Without Bypass(TTNBP),* Loss of Feedwater Heating (LFWH)," RWE, and* Feedwater Controller Failure (Maximum Demand) (FWCF).The fuel loading error is categorized as an Infrequent Incident.

However, if the licensee does notmeet the requirements of GESTAR II (Reference 4), the fuel loading error event would beanalyzed as an AOO. NMP2 does not meet the requirements of Reference
4. Therefore, the fuelloading error event is evaluated as an AOO for each reload. [[9-1 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION

-CLASS I (PUBLIC)]]The thermal margin event analysis is performed as part of the reload process for each reload coreand results are documented in the SRLR. From M+LTR SER Limitation and Condition 12.4,]] Inaccordance with Methods LTR SER Limitation and Condition 9.19, an additional 0.01 will beadded to the OLMCPR for conditions above the stretch power uprate power level or above theMELLLA boundary (MELLLA+ conditions), until such time that GEH expands the experimental database supporting the Findlay-Dix void-quality correlation to demonstrate the accuracy andperformance of the void-quality correlation based on experimental data representative of thecurrent fuel designs and operating conditions during steady-state, transient, and accidentconditions. In the event that the cycle-specific reload analysis is based on TRACG rather thanODYN for AOO, no 0.01 adder to the OLMCPR is required. In accordance with M+LTR SER Limitation and Condition 12.16, an RWE analysis wasperformed to confirm the adequacy of the generic RBM setpoints. The RWE was simulated using the three-dimensional core simulator PANACEA. The analysis was performed with anapproximate equilibrium core at the MELLLA+ 100% power, 85% CF statepoint for acomprehensive set of RBM setpoints. The results of this RWE analysis confirmed the validity ofthe generic RBM setpoints. The RWE results also meet the 1% cladding circumferential plasticstrain acceptance criterion. In accordance with Methods LTR SER Limitations and Conditions 9.9, 9.10, and 9.11,acceptable fuel rod T-M performance for both U02 and GdO2 fuel rods was demonstrated. Results for all AOO pressurization transient events analyzed, including EOOS, showed at least10% margin to the fuel centerline melt and the 1% cladding circumferential plastic strainacceptance criteria. The minimum calculated margin to the fuel centerline melt criterion forAOO pressurization transient events was 19.2%. The minimum calculated margin to thecladding strain criterion was 18.2%. Fuel rod T-M performance will be evaluated as part of theRLAs performed for the cycle-specific core. Documentation of acceptable fuel rod T-Mresponse will be included in the SRLR or COLR.9-2 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)9.1.2 Power and Flow Dependent LimitsThe operating MCPR., LHGR, and/or MAPLHGR thermal limits are modified by a flow factorwhen the plant is operating at less than 100% CF. The MCPR flow factor (MCPRf) and theLHGR flow factor (LHGRFACf) are primarily based upon an evaluation of the slowrecirculation flow increase event. [[]] Table 9-2 summarizes the results of the slowrecirculation flow increase analysis and compares them with the MCPR flow limit. Thereference limits bound the slow recirculation flow results performed for the MELLLA+operating domain. [[Similarly, the thermal limits are modified by a power factor (MCPRp) when the plant is operating at less than 100% power. 19.1.3 Non-Limiting EventsE provides anassessment of the effect of the MELLLA+ operating range expansion for each of the Reference 4limiting AOO events and key non-limiting events. Provided these evaluations are applicable toNMP2, no further evaluations are required for non-limiting events. The results of the M+LTRassessment are presented in the table below:Event Discussion Fuel Thermal Margin EventsInadvertent HPCI Start The inadvertent HPCI start event is not applicable for NMP2.Slow Recirculation Increase(Kf, MCPRf) (Reference 4 event -bounds recirculation event AOOs)Fast Recirculation Increase9-3 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)1]9.2 DESIGN BASIS ACCIDENTS AND EVENTS OF RADIOLOGICAL CONSEQUENCE 9.2.1 Design Basis EventsThis section addresses the radiological consequences of a DBA.evaluation are:The topics addressed in thisTopic M+LTR Disposition NMP2 ResultControl Rod Drop Accident [[Instrument Line Break Accident (ILBA)Main Steam Line Break Accident(MSLBA) (Outside Containment) Loss-of-Coolant Accident(Inside Containment) Large Line Break(Feedwater or Reactor Water Cleanup)Liquid Radwaste Tank FailureFuel Handling Accident (FHA)Offgas System FailureCask Drop9.2.1.1 Control Rod Drop Accident[[ ]] the radiological consequences of this DBA are evaluated to determine off-site doses as well as control roomoperator doses. DBA calculations are generally based on core inventory sources or TS sourceterms, [R]] ForEvent 1, the source term is based on fission products from failed fuel and the instantaneous transport to the condenser remains conservative for MELLLA+, therefore Event 1 is unchanged for MELLLA+. The source term for Event 2 is based on the maximum activity allowed underthe MSL radiation monitor safety limit, therefore the analyzed condition in Event 2 is boundingfor MELLLA+.The CRDA release is dependent on the source terms and maximum peaking factor. Operation inthe MELLLA+ operating domain does not affect the alternate source term (AST) CRDA source9-4 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)term and the peaking factor remains bounding. [[]] and no further evaluation is required. 9.2.1.2 Instrument Line Break Accident[[ ]] the radiological consequences of a DBA are evaluated to determine off-site doses as well as control roomoperator doses. DBA calculations are generally based upon core inventory sources or TS sourceterms, [[]] Table 9-4 of the M+LTR provides a detailedevaluation of each of the above events. [[]] then no furtherreview is required. Therefore the ILBA evaluation is not affected by the MELLLA+ operating domain expansion and no further evaluation is required. 9.2.1.3 Main Steam Line Break Accident (Outside Containment) ]] the radiological consequences of this DBA are evaluated to determine off-site doses aswell as control room operator doses. DBA calculations are generally based on core inventory sources or TS source terms, [[]] Table 9-4 of the9-5 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)M+LTR provides a detailed evaluation of the MSLBA events. [[]] then no further review is required. ]] In addition, the analysis of record for the worst-case MSLBA radiological consequences is at hot standby conditions, which is outside of the MELLLA+ operating domain.Therefore the NMP2 MSLBA evaluation is not affected by the MELLLA+ operating domainexpansion and no further evaluation is required. 9.2.1.4 Loss-of-Coolant Accident (Inside Containment) [[]]the radiological consequences of this DBA are evaluated to determine off-site doses aswell as control room operator doses. DBA calculations are generally based on core inventory sources or TS source terms, [[The design input and assumptions for suppression pool pH were previously evaluated. Thesource term assumptions are not changing for MELLLA+. In addition, the acid production termsare not changing for MELLLA+ conditions. The use of Sodium Pentaborate as a buffer perUSAR Section 15.8.3.5 continues to be appropriate. Table 9-4 of the M+LTR provides a detailed evaluation of each of the above events. [[]] then no further review is required. 9-6 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)]] Therefore, theNMP2 LOCA evaluation is not affected by the MELLLA+ operating domain expansion and nofurther evaluation is required. 9.2.1.5 Feedwater Line BreakE[ ]] the radiological consequences of a DBA are evaluated to determine off-site doses as well as control roomoperator doses. DBA calculations are generally based upon core inventory sources or TS sourceterms, [[]] Table 9-4 of the M+LTR provides a detailedevaluation of each of the above events. [[]] then no furtherreview is required. ]] Therefore the NMP2 FW Line Break evaluation isnot affected by the MELLLA+ operating domain expansion and no further evaluation is required. [[9.2.1.6 Liquid Radwaste Tank FailureThe M+LTR discussion of the liquid radwaste tank failure describes in Table 9-4 of the M+LTREr9-7 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)]] The moisture content of the MS increases in a smallarea of the MELLLA+ operating domain near the minimum CF and 100% CLTP (seeSections 3.3.4 and 8.4). Section 8.5 discusses the analysis of the radioactive nuclide inventory inthe radwaste tank. [[]] Therefore, the liquid radwaste tank failure accident does not present a radiological concern at NMP2 for operation in the MELLLA+ operating domain.Er9.2.1.7 Fuel Handling AccidentE[ r]the radiological consequences of this DBA are evaluated to determine off-site doses as well ascontrol room operator doses. DBA calculations are generally based on core inventory sources orTS source terms, [[]] Table 9-4 of the M+LTRprovides a detailed evaluation of each of the above events. [[]]then no further review is required. ErTherefore, the NMP2 FHA evaluation for the MELLLA+ operating domain is bounded by theanalysis for the current licensed operating domain, and no further evaluation is required. Er1]9.2.1.8 Offgas System FailureEr ]] theradiological consequences of a DBA are evaluated to determine off-site doses as well as controlroom operator doses. DBA calculations are generally based upon core inventory sources or TSsource terms, E[]] Table 9-4 of the M+LTR provides a9-8 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)detailed evaluation of each of the above events. [[]] then no furtherreview is required. ]] Therefore the NMP2 offgas systemfailure evaluation is not affected by the MELLLA+ operating domain expansion and no furtherevaluation is required. 1]]9.2.1.9 Cask Drop[[ ]] the radiological consequences of a DBA are evaluated to determine off-site doses as well as control roomoperator doses. DBA calculations are generally based upon core inventory sources or TS sourceterms, [[]] Table 9-4 of the M+LTR provides a detailedevaluation of each of the above events. [[]] then no furtherreview is required. ]] Therefore the NMP2 cask drop evaluation for the MELLLA+ operating domain is bounded by the analysis for the current licensed operating domain, and no furtherevaluation is required. [[I9.2.2 Other Events with Radiological Consequences This section addresses the radiological consequences of other events as described in the M+LTR.The topics addressed in this evaluation are:Topic M+LTR Disposition I NMP2 ResultNone N/A9-9 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)9.3 SPECIAL EVENTSThis section considers three special events: ATWS, SBO, and ATWS with Core Instability. Theoperator actions required as a result of ATWS are reviewed and discussed as a part ofSection 10.9. The topics addressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultATWS (Overpressure) [[ATWS (Suppression Pool Temperature and Containment Pressure) ATWS (Peak Cladding Temperature and Oxidation) Station BlackoutATWS with Core Instability 9.3.1 Anticipated Transients Without ScramThere is no change in core power, decay heat, pressure, or steam flow as a result of theMELLLA+ operating range expansion. [[]] The ATWS evaluation acceptance criteria are to:* Maintain reactor vessel integrity (i.e., peak vessel bottom pressure less than the ASMEService Level C limit of 1,500 psig)" Maintain containment integrity (i.e., maximum containment pressure lower than thedesign pressure of the containment structure and maximum suppression pool temperature lower than the pool temperature limit)* Maintain coolable core geometryPlant-specific ATWS analyses are performed to demonstrate that the ATWS acceptance criteriaare met for operation in the MELLLA+ operating domain. NMP2 meets the ATWS mitigation requirements in 10 CFR 50.62 for an alternate rod insertion (ARI) system, SLS boron injection equivalent to 86 gpm, and automatic RPT logic (i.e., ATWS-RPT). The plant-specific ATWSanalyses take credit for the ATWS-RPT and SLS. However, ARI is not credited. In accordance with M+LTR SER Limitations and Conditions 12.18.e and 12.18.f, the key inputparameters to the plant-specific ATWS analyses are provided in Table 9-3. For key inputparameters that are important to simulating the ATWS analysis and are specified in the TS(e.g., SLS parameters and ATWS-RPT), the calculation assumptions are consistent with theallowed NMP2 TS values and plant configuration. Although conservative inputs consistent withthe NMP2 TS values were used, this does not imply that ATWS is part of the TS Bases. In someinstances, nominal input parameters are used consistent with the approach in Reference 38.Reference 38 contained sensitivity studies on key parameters for information.

However, therewas no specific uncertainty treatment applied.

In addition, the EOOS assumptions for ATWS areconsistent with TS requirements. M+LTR SER Limitation and Condition 12.23.2 requires thatthe plant-specific automatic settings be modeled for ATWS. For NMP2, the plant automatic 9-10 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)settings, which include the ATWS-RPT, low pressure isolation, and SRV actuation, are modeledbased on the input parameters in Table 9-3. As required by M+LTR SER Limitation andCondition 12.23.8, the plant-specific ATWS analyses account for plant- and fuel-design-specific features including debris filters.9.3.1.1 Anticipated Transients Without Scram (Licensing Basis)The plant-specific ATWS analysis is performed using the approved ODYN methodology documented in Section 5.3.4 of ELTRI (Reference 5). The ATWS analysis using the ODYNmethodology is the plant's licensing basis for this application. A licensing basis ODYN ATWS analysis was performed to demonstrate the effect of MELLLA+on the ATWS acceptance criteria. [[The results of the licensing basis ODYN ATWS analysis are provided in Tables 9-4 and 9-5.The tabulated peak value and time trace for reactor power, reactor dome pressure, PCT andsuppression pool temperature is provided in Table 9-5 for the limiting event in the ODYNATWS analysis. For reactor power, analysis results are provided for the limiting event withrespect to peak reactor vessel pressure. The limiting event is the PRFO at EOC.]] The peak vessel bottom pressure response is dependent on several inputs,including the SRV upper tolerances assumed in the ATWS analysis. In accordance with M+LTRSER Limitation and Condition 12.23.3, [[9-11 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)]] NMP2 as-found SRV lift setpoint tests do not show a propensity for setpoint drifthigher than the 3% drift tolerance. Therefore, the SRV upper tolerances used in the ATWSanalysis are consistent with the plant-specific performance. The suppression pool temperature following an ATWS is bounded by EPU. Therefore, MELLLA+ does not affect the NPSH available for the ECCS pumps. [[]] M+LTR SERLimitation and Condition 12.23.11 requires that the use of suppression pool temperature limitshigher than the heat capacity temperature limit (HCTL) for emergency depressurization must bejustified. The containment design limit is the ATWS acceptance criteria. [[]] Per M+LTRSER Limitation and Condition 12.18.b, a best estimate TRACG analysis modeling emergency depressurization is not required if the plant increases boron-10 concentration/enrichment so thatthe integrated heat load to containment calculated by the licensing ODYN calculation does notchange with respect to a reference OLTP / 75% flow ODYN calculation. The peak containment pressure is 6.5 psig, which is below the NMP2 design limit of 45 psig. Inaccordance with M+LTR SER Limitation and Condition 12.23.10, the increase in containment pressure resulting from ATWS events with MELLLA+ operation does not adversely affectoperation of the safety-grade equipment. As discussed in Sections 4.2.6 and 10.3, safety-grade equipment has been evaluated for operation at DBA LOCA conditions; these conditions boundthe containment pressure increase following an ATWS event. Therefore, operation of safety-grade equipment is not adversely affected by the MELLLA+ operating domain expansion. A coolable core geometry is ensured by meeting the 2,200'F PCT and 17% local claddingoxidation acceptance criteria of 10 CFR 50.46. [[]]The results of the licensing basis ODYN ATWS analysis meet the ATWS acceptance criteria. Therefore, the NMP2 response to an ATWS event initiated in the MELLLA+ operating domainis acceptable. 9-12 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)9.3.1.1.1 Anticipated Transients Without Scram (Single SLS Pump)An additional plant-specific ATWS analysis is performed using the same approved ODYNmethodology as the licensing basis calculation. The purpose of the additional analysis is to showthat all ATWS acceptance criteria are met with only a single SLS pump operating. Inputparameters specific to this analysis are provided in Table 9-6. All other input parameters areconsistent with Table 9-3.The results of the single SLS pump ODYN ATWS analysis are provided in Tables 9-7 and 9-8.The tabulated peak value and time trace for reactor power, reactor dome pressure, PCT, andsuppression pool temperature is provided in Table 9-8 for the limiting event in the ODYNATWS analysis. For reactor power, analysis results are provided for the limiting event withrespect to peak reactor vessel pressure. The limiting event is the PRFO at EOC.All ATWS acceptance criteria are met at MELLLA+ conditions with only a single SLS pumpoperating. 9.3.1.2 Anticipated Transients Without Scram (Best-Estimate Calculation) The HCTL is provided in the NMP2 EOPs. The HCTL is a function of operating reactorpressure and suppression pool water level. For normal suppression pool water level, the HCTLis approximately 140'F near the SRV opening pressure. At the extreme upper suppression poolwater level covered by EOPs, the HCTL is approximately 90'F near the SRV opening pressure. NMP2 EOPs require depressurization during an ATWS event when the suppression pooltemperature reaches the HCTL. As a result, M+LTR SER Limitation and Condition 12.18.arequires that a best-estimate TRACG ATWS analysis must be performed for NMP2 because hotshutdown was not achieved prior to reaching the HCTL based on the licensing basis ODYNcalculation. M+LTR SER Limitation and Condition 12.18.c further requires that PCT beevaluated for both the initial overpressure and depressurization phases for the TRACG ATWScalculation.

However, M+LTR SER Limitation and Condition 12.18.b states that the TRACGcalculation is not required if the plant increases the boron-10 concentration/enrichment so thatthe integrated heat load to containment calculated by the licensing ODYN calculation does notchange with respect to a reference OLTP/75%

flow ODYN calculation. For NMP2, the boron-10 enrichment is increased from 25 atom % to 92 atom % at MELLLA+operating conditions. The results of the MELLLA+ licensing ODYN calculation are comparedto a reference OLTP/75% flow ODYN calculation. [[9-13 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)]]As a result of the increased boron-10 enrichment at MELLLA+, the best-estimate TRACGATWS analysis is not required to meet the ATWS acceptance criteria. 9.3.2 Station Blackout[[ ]] there is nosignificant change in core power, decay heat, pressure, or steam flow as a result of theMELLLA+ operating domain expansion. [[]] there is no change in the reactorpower level as a result of the MELLLA+ operating domain expansion. As discussed inSection 1.2.3, there is no significant change in decay heat as a result of the MELLLA+ operating domain expansion. For NMP2, there are no increases in reactor operating pressure as result ofMELLLA+ operating domain expansion. For NMP2, there are no significant changes in the MSflow rate. The numerical values showing no significant changes to reactor operating power andMS flow rate are presented in Table 1-2. [[]] No furtherevaluation is required. 9.3.3 ATWS with Core Instability The NRC has reviewed and accepted GEH's disposition of the effect of large coupled thermal-hydraulic/neutronic core oscillations during a postulated ATWS event, which is presented inNEDO-32047-A (Reference 39). The companion report, NEDO-32164 (Reference

40) wasapproved by the same NRC SER. The NRC review concluded that the GEH TRACG code is anadequate tool to estimate the behavior of operating reactors during transients that may result inlarge power oscillations.

The review also concluded that ATWS criteria, which are listed below,were met:1. Radiological consequences must be maintained within 10 CFR 100 guidelines;

2. Primary system integrity to be maintained;
3. Fuel damage limited so as not to significantly distort the core, impede core cooling, orprevent safe shutdown;
4. Containment integrity to be maintained; and5. Long-term shutdown and cooling capability to be maintained.

Furthermore, the NRC review concluded that the specified operator actions are sufficient tomitigate the consequences of an ATWS event with large core power oscillations. [[9-14 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)]]M+LTR SER Limitation and Condition 12.19 requires that a plant-specific ATWS instability calculation be performed to demonstrate that NMP2 EOP actions, including boron injection andwater level control strategy, effectively mitigate an ATWS event with large power oscillations inthe MELLLA+ operating domain. The plant-specific ATWS instability calculation was(1) based on the limiting of BOC, peak reactivity exposure condition (MOC), and EOC;(2) modeled the plant-specific configuration important to the ATWS instability response; and(3) used the limiting of the regional mode or core-wide mode nodalization scheme. M+LTRSER Limitation and Condition 12.23.5 requires that the power density be less than52.5 MWt/Mlbm/hr. For NMP2, the plant-specific maximum power-to-flow ratio at rated powerand minimum CF is 43.3 MWt/Mlbm/hr and meets the requirement. The plant-specific TRACGcalculation modeled in-channel water rod flow in accordance with M+LTR SER Limitation andCondition 12.24.1. The plant-specific ATWS instability calculation was performed using thelatest NRC-approved neutronic and thermal-hydraulic codes TGBLA06/PANAC 11 andTRACG04 (Reference 41).9-15 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)The results of the plant-specific TRACG ATWS instability calculation are provided in Table 9-9.Figures 9-9, 9-10, 9-11, and 9-12 show the mitigating effect of decreasing water level and boroninjection on the core and bundle response to both the TTWBP (for limiting pressure) and RPT(for limiting PCT) ATWS instability events.The results of the plant-specific TRACG ATWS instability calculation meet the ATWSacceptance criteria. Therefore, the NMP2 response to an ATWS with core instability eventinitiated in the MELLLA+ operating domain is acceptable. NMP2 EOP actions, including boroninjection and water level control strategy, effectively mitigate an ATWS event with large poweroscillations in the MELLLA+ operating domain.9-16 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Table 9-1 AOO Event Results SummaryFlow Peak Dome Peak Vessel Peak Neutron Peak Heat GE14(% of Rated) Event Pressure Pressure Flux Flux(psig) (psig) (%) (%Initial) ACPR (')105 LRNBP 1,255 1,283 520 133 0.3085 LRNBP 1,253 1,275 402 125 0.26105 TTNBP 1,253 1,280 511 130 0.3085 TTNBP 1,251 1,273 367 122 0.25105 FWCF 1,229 1,257 474 131 0.2885 FWCF 1,228 1,249 338 123 0.2385 LFWH (2) -(3) -(3) -(3) -(3) 0.14100 RWE _ (3) _ (3) _ (3) _ (3) 0.2985 RWE _ (3) _ (3) _ (3) -(3) 0.29Notes:(1) For the pressurization events, the uncorrected ACPR values are presented. (2) The LFWH is most limiting at low CF, and therefore, it was not analyzed at CLTP/MELLLA conditions. The event is non-limiting with respect to ACPR.(3) The PANACEA code is used to analyze slow events; therefore, system response parameters are notapplicable. 9-17 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Table 9-2 Comparison of Slow Recirculation Flow Increase Results and MCPR FlowLimitFlow (%) Slow Recirculation Flow MCPR Flow LimitIncrease MCPR112 1.13 1.25110 1.14 1.25100 1.17 1.2590 1.21 1.2580 1.25 1.3070 1.29 1.3760 1.32 1.4555 1.34 1.489-18 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Table 9-3 Key Input Parameters for ATWS AnalysesParameter CLTP MELLLA+ BasisReactor Power (MWt) 3,988 3,988Analyzed Power (MWt) 3,988 3,988Analyzed Core Flow (Mlbm/hr / % Rated) 107.4 / 99.0 92.2 / 85.0Reactor Dome Pressure (psia) 1,035 1,035MSIV Closure Time (sec) 4.0 4.0High Pressure ATWS-RPT Setpoint (psig) 1,095.0 1,095.0Low Pressure Isolation Setpoint (psig) 720.0 720.0RCIC Flow Rate (gpm) 600.0 600.0Number of SRVs / SRVOOS 18/2 18/2Each SRV Capacity at 1,145 psig (lbm/hr) 890,371 890,371SRV Analytical Opening Setpoints (psig) 1,121 -1,161 1,121 -1,161SLS Injection Location HPCS HPCSSLS Injection Rate (gpm) 82.4 80.01Boron-10 Enrichment (atom %) 25.0 92.0Sodium Pentaborate Concentration (% by Weight) 13.6 13.6SLS Liquid Transport Time (sec) 120.0 124.0'Initial Suppression Pool Liquid Volume (ft3) 145,200 145,200Initial Suppression Pool Temperature (°F) 90.0 90.0Number of RHR Suppression Pool Cooling Loops 2 2RHR Heat Exchanger Effectiveness Per Loop 249.0 265.02(BTU/sec-°F) RHR Heat Exchanger Effectiveness Per Loop 249.0 265.02during LOOP Event (BTU/sec-°F) RHR Service Water Temperature ('F) 84.0 84.0Notes:1. [[2. This value is consistent with the EPU LOCA long-term suppression pool temperature analysis. 9-19 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Table 9-4 Key Results for Licensing Basis ODYN ATWS AnalysisATWS Acceptance Criteria CLTP MELLLA+ Design LimitPeak Vessel Pressure (psig) [[ _1,500Peak Suppression Pool Temperature ('F) 190Peak Containment Pressure (psig) 45.0Peak Cladding Temperature ('F) 2,200Peak Local Cladding Oxidation (%) 2 17Peak Upper Plenum Pressure After SLSPump Startup (psia) ]]_--Notes:1. [[]]9-20 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Table 9-5 ODYN ATWS Analysis Limiting Event Results at MELLLA+Parameter Limiting Event Peak Value Time TraceReactor Power (Neutron Flux) PRFO at EOC 968% Rated Figure 9-3Reactor Dome Pressure PRFO at EOC 1,370 psia Figure 9-3Suppression Pool Temperature MSIVC at EOC 160°F Figure 9-4Peak Cladding Temperature PRFO at EOC 1,437°F Figure 9-59-21 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Table 9-6 Key Input Parameters for Single SLS Pump ATWS AnalysesParameter MELLLA+ BasisSLS Injection Rate (gpm) 40.0 ' [[SLS Liquid Transport Time (sec) 236.0'Notes:1. [[9-22 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Table 9-7 Key Results for Single SLS Pump ODYN ATWS AnalysisATWS Acceptance Criteria MELLLA+ Design LimitPeak Vessel Pressure (psig) 1,500Peak Suppression Pool Temperature (°F) 190Peak Containment Pressure (psig) 45.0Peak Cladding Temperature (0F) 2,200Peak Local Cladding Oxidation (%) 17Peak Upper Plenum Pressure After SLS Pump Startup (psia) --Notes:1. [[9-23 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Table 9-8 Single SLS Pump ODYN ATWS Analysis Limiting Event ResultsParameter Limiting Event Peak Value Time TraceReactor Power (Neutron Flux) PRFO at EOC 968% Rated Figure 9-6Reactor Dome Pressure PRFO at EOC 1,370 psia Figure 9-6Suppression Pool Temperature MSIVC at EOC 1660F Figure 9-7Peak Cladding Temperature PRFO at EOC 1,437°F Figure 9-89-24 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Table 9-9 Key Results for ATWS with Core Instability Analysis from MELLLA+Operating DomainATWS Acceptance Criteria MELLLA+ Design LimitPeak Vessel Pressure (psig) 1 [[ 1,500Peak Cladding Temperature (°F) 2,200Peak Local Cladding Oxidation (%) 2 ]] 17Notes:1. The TRACG calculation of peak vessel pressure is based on two SRVs OOS.2. [[I]9-25 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)275 [ Ne1 Fs HW 55F 70 --- Vessel DomePre..u. 1350--Awerages Surface Heat Film Safety Val'e Flow Core Inlet Flow -- ReliefVale Flow250 500 re- Turbine Btass Steam Flow60 1300225 450200 400 501250175 300S150 40 -1200S125 _250E30 1150100 2002Z75 150 20 1050 10010 105025 500 010 0 N I q i F q 10000 1 2 3 4 5 6 70 1 2 3 4 5 6 7Time (s) Time (5)125 Vese Le 60 10 Void Reactl-A&- Vessel Lream Flow -S- .nram Readlly-S- Feedweter Flow -- Doppler ReactMt"50_G T'urbine Steam Flow Total React"~t75 4050 so25 20~. .S -200 10-25 0-50 4 40 Ia 1 2 3 4 5 6 7 0 1 2 3 4 5 6 7Time (s) Time (s)PID: 50163Figure 9-1 LRNBP at ICF9-26 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)20017515012515025012510075so01251070605040302015013501300125012002~1155011100105010S0Time (s)Time (S)RD:50163Figure 9-2 LRNBP at MELLLA+9-27 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Figure 9-3 ODYN ATWS Analysis -PRFO at EOC Short-Term Results9-28 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Figure 9-4 ODYN ATWS Analysis -MSIVC at EOC Long-Term Results9-29 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)[RFigure 9-5 ODYN ATWS Analysis -PRFO at EOC PCT9-30 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Figure 9-6 Single SLS Pump ODYN ATWS Analysis -PRFO at EOC Short-Term Results9-31 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)111]Figure 9-7 Single SLS Pump ODYN ATWS Analysis -MSIVC at EOC Long-Term Results9-32 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Figure 9-8 Single SLS Pump ODYN ATWS Analysis -PRFO at EOC PCT9-33 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Figure 9-9 ATWS Instability from MELLLA+ Operating Domain -Turbine Trip withFull Bypass9-34 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)]Figure 9-10 ATWS Instability from MELLLA+ Operating Domain -Turbine Trip withFull Bypass9-35 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)I]Figure 9-11 ATWS Instability from MELLLA+ Operating Domain -Recirculation PumpTrip9-36 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)[[IFigure 9-12 ATWS Instability from MELLLA+ Operating Domain -Recirculation PumpTrip9-37 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)10.0 OTHER EVALUATIONS This section addresses the evaluations in Section 10 of the M+LTR.10.1 HIGH ENERGY LINE BREAKHELBs are evaluated for their effects on equipment qualification. The topics addressed in thisevaluation are:TopicSteam LinesBalance-of-Plant Liquid LinesOther Liquid LinesM+LTR Disposition NMP2 Result1]10.1.1 Steam LinesMELLLA+ operating domain expansion has no effect on the steam pressure or enthalpy at thepostulated steam line break locations. The MS enthalpy will be slightly lower for MELLLA+and hence the EPU HELB subcompartment analyses are bounding for MELLLA+. [[]] a review of the heat balancesproduced for NMP2 MELLLA+ operating domain expansion confirms that there is no significant effect on the steam pressure or enthalpy at the postulated break locations (e.g., MS and RCIC).10.1.2 Balance-of-Plant Liquid Lines[[ 1]MELLLA+ operating domain expansion has no effect on the steam pressure or enthalpy at thepostulated FW line break locations. [[]] a review of the heat balancesproduced for MELLLA+ confirms that there is no effect on the liquid line conditions at thepostulated FW break locations. [[10-1 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)10.1.3 Other Liquid Lines]] The scope of theseevaluations includes MELLLA+ operating domain expansion effects on subcompartment pressures and temperatures, pipe whip, jet impingement, and flooding, consistent with the plantlicensing basis.[[ ]] a review of the heat balancesproduced for the NMP2 MELLLA+ operating domain confirms that there is no effect on theliquid line conditions (excluding FW addressed in Section 10.1.2) at the postulated breaklocations. [[]] The scope of these evaluations includes MELLLA+ operating domainexpansion effects on subcompartment pressures and temperatures, pipe whip, jet impingement, and flooding, consistent with the plant licensing basis. [[]]10.2 MODERATE ENERGY LINE BREAKModerate energy line breaks (MELBs) are evaluated for their effects on equipment qualification. NMP2 uses the MELB equivalent term moderate energy line crack (MELC). The topicsaddressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultFloodingEnvironmental Qualification 10.2.1 Flooding]] a review of the NMP2 auxiliary flowrates and system inventories shows that MELLLA+ operating domain expansion does not affectthe flow rates of moderate energy piping systems. Also, for NMP2, no operational modesevaluated for MELB are affected by MELLLA+ operating domain expansion. [[10-2 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)1]10.2.2 MELB Environmental Qualification ]] a review of the NMP2 auxiliary flowrates and system inventories shows that MELLLA+ operating domain expansion does not affectthe flow rates of moderate energy piping systems. Also, for NMP2, no operational modesevaluated for MELB are affected by MELLLA+ operating domain expansion. [[10.3 ENVIRONMENTAL QUALIFICATION Safety-related components are required to be qualified for the environment in which theyoperate. The topics addressed in this evaluation are:TopicElectrical Equipment Mechanical Equipment with Non-Metallic CoMechanical Component Design Oualification M+LTR Disposition NMP2 Result[[I___________ 1110.3.1 Electrical Equipment there is no change or increase in core power, radiation levels, decay heat, pressure, steam flow,or FW flow as a result of the MELLLA+ operating domain expansion. [[]] No further evaluation isrequired for EQ of electrical equipment as a result of MELLLA+ operating domain expansion. [[ ]] the reactor power does notincrease as a result of MELLLA+ operating domain expansion. There is no change in normal10-3 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)operation radiation levels (see Section 8.5). There is also no change in decay heat (seeSection 1.2.3). For NMP2, there are no increases in reactor operating

pressure, MS or FW flowrates. The numerical values showing no increases in reactor operating
pressure, MS or FW flowrates are presented in Table 1-2. [[]] No further evaluation is required for EQ ofelectrical equipment as a result of MELLLA+ operating domain expansion.

[[10.3.2 Mechanical Equipment With Non-Metallic Components [r]] operation in the MELLLA+ operating domain does not increaseany of the normal process temperatures. [[]] No further evaluation is required for EQ of mechanical equipment with non-metallic components as a result of the MELLLA+ operating domain expansion. [[ ]] for NMP2, normal processtemperatures are not affected by MELLLA+. [[]] No furtherevaluation is required for EQ of mechanical equipment with non-metallic components as a resultof the MELLLA+ operating domain expansion. Er10.3.3 Mechanical Component Design Qualification [[]] operation in the MELLLA+ operating domain does not affect any ofthe normal process temperatures, pressures, or flow rates. [[]] The change in fluidinduced loads on safety-related components is discussed in Sections 3.2.2, 3.5, and 4.1.2. [[10-4 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)]] for NMP2, normal processtemperatures, pressures, and flow rates are not affected by MELLLA+. There is no change inradiation levels (see Section 8.5). [[10.4 TESTINGWhen the MELLLA+ operating domain expansion is implemented, testing is recommended toconfirm operational performance and control aspects of the MELLLA+ changes. The topicsaddressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultSteam Separator-Dryer Performance [[APRM Calibration Core Performance Pressure Regulator Water Level Setpoint ChangesNeutron Flux Noise Surveillance 10.4.1 Steam Separator-Dryer Performance The performance of the steam separator-dryer (i.e., MCO) is determined by a test similar to thatperformed in the original startup test program. Testing will be performed near the CLTP and theMELLLA+ minimum CF statepoint of 85% as well as other statepoints that may be deemedvaluable for the purpose of defining the MCO magnitude and trend.10.4.2 Average Power Range Monitor Calibration The APRM system is calibrated and functionally tested. The APRM STP scram and rod blockare calibrated with the MELLLA+ equations and the APRM trips and alarms tested. This testwill confirm that the APRM trips, alarms, and rod blocks perform as intended in the MELLLA+operating domain.10.4.3 Core Performance The core performance test will evaluate the core thermal power, fuel thermal margin, and CFperformance to ensure a monitored approach to CLTP in the MELLLA+ operating domain.Measurements of reactor parameters are taken in the MELLLA+ operating domain. Corethermal power and fuel thermal margin are calculated using accepted methods. Aftersteady-state conditions are established, measurements will be taken, core thermal power and fuelthermal margin calculated, and evaluated against projected values and operational limits.10-5 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)10.4.4 Pressure Regulator The pressure regulator test will confirm that the pressure control system settings established foroperation at CLTP are adequate in the MELLLA+ operating domain. The pressure regulator should not require any changes from the settings established for the current licensed operating domain. The pressure control system response to pressure setpoint changes is determined bymaking a down setpoint step change and, after conditions stabilize, an upward setpoint stepchange.10.4.5 Water Level Setpoint ChangesThe water level setpoint changes test verifies that the FW control system can provide acceptable reactor water level control in the MELLLA+ operating domain. Reactor water level setpoint stepchanges are introduced into the FW control system, while the plant response is monitored. 10.4.6 Neutron Flux Noise Surveillance The neutron flux noise surveillance test verifies that the neutron flux noise level in the reactor iswithin expectations in the MELLLA+ operating domain. The noise will be recorded bymonitoring the LPRMs and APRMs at steady-state conditions in the MELLLA+ operating domain.10.5 INDIVIDUAL PLANT EXAMINATION This section provides an assessment of the risk increase, including core damage frequency (CDF)and large early release frequency (LERF), associated with operation in the MELLLA+ range.The topics addressed in this evaluation are:M+LTRTopic Disposition NMP2 ResultInitiating Event Categories and Frequency [IComponent Reliability Operator ResponseSuccess CriteriaExternal EventsShutdown RiskPRA Quality ]]In accordance with M+LTR SER Limitation and Condition 12.21, a plant-specific probabilistic risk assessment (PRA) evaluation was performed, which included CDF and LERF effectsassociated with operation in the MELLLA+ operating domain. The evaluation scope included allof the elements of Section 10.5, Individual Plant Examination, of the M+LTR (Reference 1).The associated PRA report is provided as Attachment 4 to the NMPNS MELLLA+ LAR.The proposed MELLLA+ operating region for NMP2 has been reviewed to determine the effecton the PRA. The PRA is based on the EPU MELLLA operating region and includes internalevents as well as fire and seismic initiating events. The effect of MELLLA+ on the PRA is very10-6 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)low and meets NRC guidelines in RG 1.174 (Reference

43) for CDF and LERF. MELLLA+ hasno effect on the risk associated with accidents initiated during shutdown conditions.

The estimated risk increase for at-power events due to MELLLA+ is a delta CDF of 1E-8 anddelta LERF of 3E-9. This represents a very small risk change in RG 1.174 (Reference 43).Based on these results, the proposed MELLLA+ operating region is acceptable on a risk basis.Risk Metric NMP2 EPU MELLLA+ Risk IncreaseCDF 3.77E-6 3.78E-6 IE-8LERF 3.92E-7 3.95E-7 3E-9Sensitivity analyses results also demonstrate a low risk with CDF and LERF changes no morethan 1E-7.10.5.1 Initiating Event Categories and Frequency The MELLLA+ core operating range expansion involves changes to the operating power/core flow map and a small number of setpoints. There is no change in the operating

pressure, power,steam flow rate, and FW flow rate. MELLLA+ implementation does not include changes toplant hardware or operating procedures that would create additional event categories or have asignificant effect on initiating event frequencies.

]]As noted in Section 2.4, the BSP, which is considered a part of the DSS-CD stability

solution, may be used when the OPRM system is temporarily inoperable.

[[1]10.5.2 Component and System Reliability [[]] There is no change in the operating

pressure, power, steam flowrate, and FW flow rate. The MELLLA+ core operating range expansion does not require majorplant hardware modifications.

[[]] TheTS ensure that plant and system performance parameters are maintained within the values10-7 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)assumed in the safety analyses. The TS setpoints, AVs, operating limits, and the like are selectedsuch that the equipment parameter values are equal to or more conservative than the values usedin the safety analyses. [[]]10.5.3 Operator ResponseThe operator responses to anticipated occurrences, accidents, and special events for EPU withMELLLA+ conditions are basically the same as for EPU conditions. Minor changes to ATWSoperator response in the PRA has occurred due to small reductions in timing for operator actionsduring an ATWS event. [[1]Because decay heat is unchanged, the time for boil-off is unchanged. Therefore, long-term corecooling is not affected by the MELLLA+ operating range expansion. ]] The minimum operatoraction time to initiate SLS is 2 minutes and the minimum operator action time to inhibit ADSand start water level reduction, if necessary, (i.e., motor-driven FW pump nuclear power plants)is 90 seconds in ATWS analyses (Section 9.3.1). SLS initiation is automatic at NMP2, thuscritical operator action to initiate SLS is not required in the NMP2 PRA. The minimum operatoraction time to inhibit ADS and start water level reduction is potentially

reduced, but this wasfound to have an insignificant effect on risk.[[I10.5.4 Success CriteriaSystems success criteria credited in a PRA to perform the critical safety functions were analyzedbased on MELLLA+.

Reactor thermal power, operating

pressure, steam flow, and FW flow arenot changed by MELLLA+.

The power conversion

systems, electrical
systems, and otherauxiliary systems are not changed as a result of MELLLA+ operation.

Also, MELLLA+ doesnot change the operating conditions of systems modeled in the PRA. There is no effect on thesuccess criteria provided for the critical safety functions in the PRA; reactivity

control, pressurecontrol, inventory control at high pressure, emergency depressurization, inventory control at lowpressure and containment heat removal; the following summarizes:

10-8 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)1) Reactivity Control -The number of control rods and reactor protection system (RPS)success criteria is unchanged. One of two SLS pumps as a successful alternate shutdownsystem is unchanged, and in fact, this success criterion is further supported by the MELLLA+evaluations and the increase in boron-10 enrichment. Although MELLLA+ has no effect onthe probability of scram failure, the plant may be at a slightly higher power during ATWSuntil SLS is injected. This can affect the timing of operator response as described inSection 3.2.5 of Attachment 4 to the NMPNS MELLLA+ LAR.2) Pressure Control (RPV Overpressure Protection) -There is no effect on the number ofSRVs required for success. RPV dome operating pressure is not increased and there is noeffect for non-ATWS events. The higher power condition during ATWS was evaluated andthe assumed success criteria (16 of 18 SRVs required) in the PRA is still met withMELLLA+ conditions. GEH analysis indicates margin in over pressure protection with twoSRVs OOS; therefore, the probability of overpressure due to failure of several SRVs is stilldominated by common cause failure of the SRVs, which is unchanged in the PRA.3) Pressure Control (SRVs Reclose) -The success criteria is that all SRVs reclose, which isunchanged. There is no effect on the number of SRV challenges for non-ATWS events asoperating pressure and power is not changed.

However, the SRVs are likely open for alonger time during ATWS due to higher initial power level. The NMP2 turbine bypass israted at approximately 18.5% of rated steam flow. Thus, until power level is reduced to theequivalent bypass flow rate, SRVs will be open. In the case of a more severe transient suchas closure of all MSIVs, SRVs will be open until SLS is injected;
however, the increased boron-10 enrichment ensures that the time to reactor shutdown is not increased due toMELLLA+.

The potential increase in probability of a stuck open SRV in the ATWS modelis considered with regard to PRA model change (see Section 3.3 of Attachment 4 to theNMPNS MELLLA+ LAR).4) High Pressure Injection -There is no change in the number of pumps required for success.The MELLLA+ plant changes do not result in changes to injection

systems, and reactorpower and pressure are unchanged.

Thus, there is no effect on injection system successcriteria for non-ATWS events. The potential for higher power level during ATWS until SLSinjection does not affect the systems credited for initial level control. The timing associated with operator response is evaluated (see Sections 3.2.5 and 3.3 of Attachment 4 to theNMPNS MELLLA+ LAR).5) Emergency Depressurization -There is no change in the number of SRVs required tosupport low pressure injection success. MELLLA+ does not involve changes to the ADS anddoes not change reactor power or pressure. Although ATWS power is potentially higheruntil SLS is injected, there is no effect on success criteria. The timing associated withoperator response is evaluated (see Sections 3.2.5 and 3.3 of Attachment 4 to the NMPNSMELLLA+ LAR).6) Low Pressure Injection -There is no change in the systems and number of pumps requiredfor success. The MELLLA+ plant changes do not result in changes to injection

systems, andreactor power and pressure are unchanged.

Thus, there is no effect on injection system10-9 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)success criteria for non-ATWS events. The potential for slightly higher power level duringinitial stages of ATWS does not affect the systems credited for level control after emergency depressurization and during SLS injection.

7) Containment Heat Removal -There is no change to the systems and success criteria forthis function.

Plant changes for MELLLA+ do not result in changes to containment heatremoval systems, and reactor power and pressure are unchanged. Thus, there is no effect onheat removal success criteria for non-ATWS events. Also, for mitigated ATWS events (SLSinjection), the RHR success criteria are unchanged. The potential reduction in time to alignRHR is considered in Section 3.2.5 of Attachment 4 to the NMPNS MELLLA+ LAR.Although the suppression pool heat-up could be initially faster during ATWS due topotentially higher power level, the SLS increased boron-10 enrichment maintains theintegrated containment heat up unchanged.

8) Containment Response

-Containment analysis for LOCA and ATWS under MELLLA+conditions indicate the dynamic loads and containment conditions remain acceptable. Noeffect on the PRA was identified (see Section 3.2.7 "Level 2 Model" of Attachment 4 to theNMPNS MELLLA+ LAR).The operating range expansion involves changes to the operating power/core flow map and asmall number of setpoints. There is no change in the operating

pressure, power, steam flow rate,and FW flow rate. The MELLLA+ operating range expansion does not impose any additional requirements on any of the safety, BOP, electrical, or auxiliary systems.

Adequate SRV capacityis provided to ensure that the ATWS overpressure requirement for MELLLA+ is satisfied. Therefore, MELLLA+ operating range expansion will not affect the PRA success criteria. 10.5.5 External EventsThe operating range expansion is not expected to affect the elements of an internal event PRA, asdiscussed in Sections 10.5.1 to 10.5.4. Therefore, there is no effect on the external events PRA.10.5.6 Shutdown RisksThe operating range expansion does not change the shutdown conditions; therefore, it has noeffect on the plant PRA shutdown risks.10.5.7 PRA QualityMELLLA+ does not have a significant effect on any PRA elements. The NMP2 PRA underwent an Internal Events and Internal Flooding industry peer review in August 2009 utilizing ASME/ANS RA-Sa-2009 and RG 1.200 Revision 2 (Reference 44). Subsequent post-peer review updates to the PRA have resolved most observations as well as incorporated the effect ofEPU. The remaining open observations were reviewed with respect to this application and werefound to have a negligible risk effect.Besides including EPU, the NMP2 PRA scope also includes the results of the individual plantexamination of external events (IPEEE) for fires and seismic initiating events at power. Thequality of the External Events modeling has not been peer reviewed against RG 1.200 Revision 2(Reference

44) and ASME/ANS RA-Sa-2009;
however, the quality was found acceptable for the10-10 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION

-CLASS I (PUBLIC)NMP2 emergency diesel generator (EDG) allowable outage time (AOT) application approved bythe NRC in 2011 (Reference 45). Also, the risk effect associated with the MELLLA+ operating range on external events risk is minimal.10.6 OPERATOR TRAINING AND HUMAN FACTORSSome additional training is required to prepare for NMP2 operation in the MELLLA+ operating domain. The topics addressed in this evaluation are:Topic I M+LTR Disposition NMP2 ResultOperator Training and Human Factors 1 ]]The description of the Operator Training and Human Factors topic in the M+LTR describes thatthe operator training program and plant simulator will be evaluated to determine the specificchanges required. The selection of training topics, operator

training, the control roommodifications, and simulator modifications are within the scope of the Licensee.

Requiredchanges are part of the MELLLA+ implementation plan and will be made consistent with theLicensee's current plant training program requirements. These changes will be made consistent with similar changes made for other plant modifications and include any changes to TS, EOPs,and plant systems.The operator responses to anticipated occurrences, accidents, and special events are notsignificantly affected by operation in the MELLLA+ domain. Significant events result inautomatic plant shutdown (scram). Some events result in automatic RCPB pressure relief, ADSactuation and/or automatic ECCS actuation (for low water level events). MELLLA+ operating domain expansion does not cause changes in any of the automatic safety functions. After theautomatic responses have initiated, the operator actions for plant safety (e.g., maintaining safeshutdown, core cooling, and containment cooling) do not change for MELLLA+ operating domain expansion. As part of the NMPNS MELLLA+ LAR, the SLS has been modified by increasing the isotopicenrichment of boron-10 in the sodium pentaborate solution as described in Section 6.5. Thisresults in an effect in the ATWS response and is evaluated in Section 9.3. 1.Consistent with the requirements for the plant-specific analysis as described in the M+LTR, theoperator training program and plant simulator will be evaluated to determine the specific changesrequired. Simulator changes and fidelity validation will be performed in accordance withapplicable ANSI standards currently being used at the training simulator. Section 10.9 addresses the MELLLA+ operating domain effects on the EOPs and the abnormal operating procedures (AOPs). Operators will be trained regarding changes to procedures, including the limitation tonot perform LPRM calibrations in the prohibited region to the left of the line illustrated onFigure 5-1.The primary effects of MELLLA+ operating domain expansion on MCR operation involvechanges to the power/flow map. Other than the changes to the computer display for thepower/flow map, there are no major physical changes to the MCR controls,

displays, or alarms asa result of MELLLA+ operating domain expansion.

Some changes are required to MCR panel10-11 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)board alarm settings and automatic actuation setpoints to accommodate changes due toMELLLA+ operating domain expansion. The SLS modification to increase the isotopicenrichment of boron-10 in the sodium pentaborate solution (as described in Section 6.5) resultsin a reduction in solution storage tank minimum required volume and associated alarm level.These changes do not affect human factors.The APRM STP scram and rod block AVs are also being changed as a result of MELLLA+operating domain expansion. These changes are described in Section 5.3.The SLS is modified by: (1) increasing the boron-10 enrichment in the sodium pentaborate solution in the SLS; (2) decreasing the sodium pentaborate solution volume stored in the SLSstorage tank; (3) reducing the injection flow requirement for ATWS response from two SLSpumps to one pump required to meet 10 CFR 50.62 for ATWS mitigation, though both SLSpumps would actually operate during an event; and (4) modifying instrumentation setpoints. The changes required to adopt the MELLLA+ power/flow map, DSS-CD (including automatic actuation setpoints), and the modifications to SLS are implemented as design changes inaccordance with the NMP2 approved change control procedures. The change control processincludes a review by operations and training personnel. Training and implementation requirements are identified and tracked, including effects on the simulator. Verification oftraining is required as part of the design change closure process.There are no planned upgrades of controls,

displays, or alarms from analog to digital instruments as part of MELLLA+ operating domain expansion.

There are no changes to the analog anddigital inputs for the safety parameter display system (SPDS) for MELLLA+ operating domainexpansion. Training required to operate NMP2 following the MELLLA+ operating domain expansion willbe conducted prior to operation in the MELLLA+ domain. Training for the MELLLA+ startuptesting program will be performed using "just in time" training of plant operation personnel where appropriate. Data obtained during operation in the MELLLA+ domain will beincorporated into additional

training, as needed. The classroom training will cover variousaspects of MELLLA+ operating domain expansion, including changes to the power/flow map,changes to important setpoints, changes to plant procedures, and startup test procedures.

Theclassroom training may be combined with simulator training for normal operational sequences unique to operation in the MELLLA+ domain. The plant dynamics do not change substantially for operation in the MELLLA+ domain. Enhanced training on ATWS event mitigation in theMELLLA+ domain, FW pump trip transient, and RPT transient will be conducted. The evaluation of the NMP2 operator training and human factors is consistent with the guidancepresented in the M+LTR and meets current industry standards. 10.7 PLANT LIFEThe plant life evaluation identifies degradation mechanisms influenced by increases in fluenceand flow rate. The topics addressed in this evaluation are:10-12 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Topic M+LTR Disposition NMP2 ResultIrradiated Assisted Stress Corrosion Cracking (IASCC)Flow Accelerated Corrosion 10.7.1 Irradiated Assisted Stress Corrosion CrackingWith regard to IASCC, the M+LTR states that the longevity of most equipment is not affected bythe MELLLA+ operating domain expansion. The peak fluence experienced by the reactorinternals may increase, representing a minor increase in the potential for IASCC. Therefore, thecurrent inspection strategy for the reactor internal components is adequate to manage anypotential effects of MELLLA+.Section 3.2.1 provides an evaluation of the change in fluence experienced by the reactorinternals. The change in fluence is minor, resulting in an insignificant change in the potential forIASCC. Therefore, the current inspection strategy based on the BWRVIP (Reference

46) issufficient to address the small increase in fluence.Fluence calculations performed at MELLLA+ conditions as required by M+LTR SER Limitation and Condition 12.22 indicate that only the top guide and shroud exceed the 5E20 n/cm2 threshold value for IASCC. The core plate fluence was calculated to be 5.95E20 n/cm2, however, whilethis value is slightly above the IASCC threshold, it is actually a decrease from the permitted CLTP value, thus it has no effect. In-core instrumentation dry tubes and guide tubes are includedin the evaluation due to an existing identification as being susceptible to IASCC in BWRVIP-47 (Reference 47).The increase in fluence due to MELLLA+ does cause an increased potential for IASCC.However, the inspection strategies and inspections recommended by BWRVIP-25, 26, 47, and76 (References 48, 49, 47, and 46, respectively) are based on component configuration and fieldexperience and this inspection program is considered adequate to address the increase inpotential for IASCC in the top guide, shroud, and in core instrumentation dry tubes and guidetubes.The BWRVIP evaluated the failure modes and effects of reactor vessel internals and published the results in BWRVIP-06 (Reference 50). This evaluation for the shroud concluded that theinspections and evaluations performed in response to Generic Letter (GL) 94-03 (Reference 51)provided conservative assurance that the shroud is able to perform its safety function.

Theinspections of the shroud and top guide are conducted using the guidance of BWRVIP-26, 76,and 183 (References 49, 46, and 52, respectively). These guidelines in the areas of detection, inspection, repair or mitigation ensure the long-term function of these components. 10.7.2 Flow Accelerated Corrosion [[]] for MELLLA+, there is no increase in the MS flow rate and temperature, and the FWflow rate and temperature. As described in Section 3.3.3, the MCO may increase in the MSLs.If this occurs, it may slightly increase the FAC rates for a small period of time during the cyclewhen the plant is operating at or near the MELLLA+ minimum CF. [[10-13 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)1]The Maintenance Rule also provides oversight for the other mechanical and electrical components important to plant safety, to guard against age-related degradation. Therefore, nofurther evaluation of this topic is required per the M+LTR.[I ]] for NMP2, there are no significant changes in MS or FW temperatures and MS or FW flow rates. As discussed in Section 3.3.3,there is an increase in MCO during the cycle for a short duration. This increase in MCO has nosignificant effect on FAC parameters. Therefore, there is no significant change in the potential for FAC in the MS system.The evaluation of and inspection for flow-induced erosion/corrosion in piping systems affectedby FAC is addressed by compliance with NRC GL 89-08. The requirements of GL 89-08 areimplemented at NMP2 by utilization of the Electric Power Research Institute generic program,"CHECWORKSTM. NMP2-specific parameters are entered into this program to developrequirements for monitoring and maintenance of specific system piping. No changes arerequired to the NMP2-specific parameters that are entered into the CHECWORKSTM program.The FAC monitoring programs are adequate to manage potential effects of MELLLA+ operating domain expansion. In addition to FAC, a periodic non-destructive examination program was established to inspectsafety-related piping and heat exchangers at known or suspected high corrosion, biofouling orsilt buildup areas in response to GL 89-13. This program is supplemented by visual inspections of opened piping and heat exchangers whenever possible. The Maintenance Rule also provides oversight for other mechanical and electrical components important to plant safety, to monitor performance and guard against age-related degradation. The longevity of NMP2 equipment is not affected by the MELLLA+ operating domainexpansion. [[ ]], and Section 3.3.4.e, the MCO for NMP2 mayincrease to a maximum value of 0.25 wt.% for a period of time during the cycle when NMP2 isoperating at or near the MELLLA+ minimum CF rate. The EPU FAC evaluation for steampiping assumed a 0.25 wt.% MCO, which bounds the maximum predicted 0.236 wt.% MCO inthe MELLLA+ operating domain. NMP2 implements programs adequate to manage this changein the erosion/corrosion rate. [[10-14 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)10.8 NRC AND INDUSTRY COMMUNICATIONS The topic addressed in this evaluation is:Topic M+LTR Disposition NMP2 ResultPlant Disposition of NRC and Industry Communications ]] NRC and industry communications could affect the plant design and safetyanalyses. As discussed in Section 1.0, the MELLLA+ operating domain expansion has a limitedeffect on the safety evaluations and system assessments. Because the maximum thermal powerand CF rate do not change for MELLLA+ operating domain expansion, the effect of the changesis limited to the NSSS, primarily within the core. The evaluations and calculations included inthis M+SAR, along with any supplements, demonstrate that the MELLLA+ operating domainexpansion can be accomplished within the applicable design criteria. Because these evaluations of plant design and safety analyses inherently include any effect as a result of NRC and industrycommunications, it is not necessary to review prior communications and no additional information is required in this area.1]10.9 EMERGENCY AND ABNORMAL OPERATING PROCEDURES EOPs and AOPs can be affected by MELLLA+ operating domain expansion. The topicsaddressed in this evaluation are:Topic M+LTR Disposition NMP2 ResultEmergency Operating Procedures [[Abnormal Operating Procedures 10.9.1 Emergency Operating Procedures EOPs include variables and limit curves which define conditions where operator actions areindicated. The EOPs remain symptom-based and thus the operator actions remain unchanged. MELLLA+ operating domain expansion is not expected to affect the NMP2 EOPs. However, inaccordance with M+LTR SER Limitation and Condition 12.23.4, the EOPs will be reviewed forany effect and revised as necessary prior to implementation of MELLLA+ operating domainexpansion. Any changes identified to the EOPs will be included in the operator training to beconducted prior to implementation of MELLLA+. The ATWS calculation performed forMELLLA+ was based on the NMP2 operator actions from the EOPs.10.9.2 Abnormal Operating Procedures NMP2 refers to AOPs as special operating procedures (SOPs). SOPs include event basedoperator actions. No significant SOP revisions are expected as a result of MELLLA+ operating domain expansion.

However, the SOPs will be reviewed for any effect and revised as necessary prior to implementation of MELLLA+ operating domain expansion.

Any changes identified to10-15 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)the SOPs will be included in the operator training to be conducted prior to implementation ofMELLLA+.10-16 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)11.0 LICENSING EVALUATIONS The licensing evaluations addressed in this section include:* Effect on TS" Environmental Assessment

  • Significant Hazards Consideration Assessment 11.1 EFFECT ON TECHNICAL SPECIFICATIONS The NMP2 TS that are affected by a MELLLA+ operating domain expansion are provided in theNMPNS MELLLA+ LAR. The implementation of MELLLA+ requires revision of a limitednumber of the NMP2 TS, including a prohibition on the intentional operation with only a singlerecirculation loop in operation while in the MELLLA+ operating domain, as defined in theCOLR. In addition, changes to the NMP2 TS are required to incorporate the DSS-CD stability solution option and changes to the SLS (including increasing the boron-10 isotopic enrichment inthe sodium pentaborate
solution, decreasing the minimum net volume stored in the SLS tank, andincreasing the SLS pump discharge pressure requirements).

11.2 ENVIRONMENTAL ASSESSMENT The environmental effects of MELLLA+ operating domain expansion are controlled at the samelimits as the current analyses. None of the present limits for plant environmental releases areincreased as a consequence of MELLLA+ operating domain expansion. MELLLA+ has noeffect on the non-radiological elements of concern, and the plant will be operated in anenvironmentally acceptable manner as documented by the Environmental Assessment forNMP2's current licensed operating domain. Existing

federal, state, and local regulatory permitspresently in effect accommodate the MELLLA+ operating domain expansion withoutmodification.

The evaluation of the effects of MELLLA+ operating domain expansion on normal radiological effluents is included in Section 8.0. There will be no change in the radiological effluents released to the environment due to the MELLLA+ operating domain expansion. The normaleffluents and doses remain well within the 10 CFR 20 limits and the 10 CFR 50 Appendix Iguidance. There is no change to the predicted doses from postulated accidents and the10 CFR 50.67 dose criteria continue to be met. In addition, the quantity of spent fuel does notincrease as a result of MELLLA+ operating domain expansion. The environmental evaluations also demonstrate that the MELLLA+ changes qualify for acategorical exclusion not requiring an environmental assessment in accordance with10 CFR 51.22(c)(9). See the NMPNS MELLLA+ LAR for an evaluation of the10 CFR 51.22(c)(9) criteria. 11-1 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)11.3 SIGNIFICANT HAZARDS CONSIDERATION ASSESSMENT Increasing the operating domain can be done safely within plant-specific limits, and is a highlycost effective way to provide needed flexibility in the generating capacity. The M+SARprovides the safety analyses and evaluations to justify expanding the CF rate operating domain.DSS-CD introduces an enhanced detection algorithm, the CDA, which reliably detects theinception of power oscillations and generates an early power suppression trip signal prior to anysignificant oscillation amplitude growth and MCPR degradation. The SLS is used to mitigate the consequences of an ATWS event and is used to limit theradiological dose during a LOCA. The proposed changes do not affect the capability of the SLSto perform these two functions in accordance with the assumptions of the associated analyses. The ATWS evaluation with the proposed changes incorporated demonstrated that all the ATWSacceptance criteria are met. The ability of the SLS to mitigate radiological dose in the event of aLOCA is not affected by these changes. The increase in the boron-10 enrichment in the sodiumpentaborate solution for the SLS is sufficient to reduce the injection flow requirement from twoSLS pumps to one. This result represents an increase in SLS redundancy. In the event of asingle SLS pump failure during a postulated ATWS, a single SLS pump will be capable ofproviding the design sodium pentaborate solution flow, thereby increasing safety margin.NMPNS currently requires two SLS pumps and is not proposing any changes to LimitingCondition for Operation (LCO) 3.1.7 or to the completion time of Required Action A.1 ofTS 3.1.7 to reflect this additional marginA complete Significant Hazards Consideration Assessment is provided in the NMPNSMELLLA+ LAR.11.3.1 Modification SummaryThe MELLLA+ core operating domain expansion does not require major plant hardwaremodifications. The core operating domain expansion involves changes to the operating power/core flow map, minor system modifications, procedure

changes, and changes to a smallnumber of instrument setpoints.

Because there is no change in the operating

pressure, power,steam flow rate, and FW flow rate, there are no major modifications to other plant equipment.

The stability solution is being changed from Option III to the DSS-CD solution. The DSS-CDsolution algorithm, licensing basis, and application procedures are generically described inNEDC-33075P (Reference 2), and are applicable to NMP2. The DSS-CD solution uses the samehardware as the current Option III solution. To support this change, a new computer (i.e., theNUMAC interfacing computer) will be installed to convert the proprietary encrypted signal fromthe PRNM system, and supply the converted signal to NMP2's current processing computer. The boron-10 enrichment in the sodium pentaborate solution in the SLS is increased from> 25 atom percent to > 92 atom percent. The increase in the boron-10 enrichment in the sodiumpentaborate solution for the SLS is sufficient to: (1) decrease the sodium pentaborate solutionvolume stored in the SLS storage tank; and (2) maintain the ATWS margin equivalent to theOLTP/75% flow basis and address the GEH SC 10-13 dilution flow safety communication (Reference 53). The higher enrichment also increases margin by meeting 10 CFR 50.62 for11-2 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)ATWS mitigation based on a single SLS pump, although TS requirements and LCO are notrelaxed. In addition, SLS tank level instrument setpoints will be changed to account for thereduced SLS tank minimum volume related to the change to > 92 atom percent boron-10enrichment. 11.3.2 Discussion of MELLLA+ IssuesPlant performance and responses to hypothetical accidents and transients have been evaluated forthe MELLLA+ operating domain expansion license amendment. This section summarizes theplant reactions to events evaluated for licensing the plant, and the potential effects on variousmargins of safety, and thereby concludes that no significant hazards consideration will beinvolved. 11.3.2.1 MELLLA+ Analysis BasisThe MELLLA+ safety analyses are based on a RG 1.49 (Reference

54) power factor times therated power level, except for some analyses that are performed at nominal rated power, eitherbecause the RG 1.49 power factor is already accounted for in the analysis methods or RG 1.49does not apply.11.3.2.2 Fuel Thermal LimitsNo change is required in the mechanical fuel design to meet the plant licensing limits whileoperating in the MELLLA+ domain. No increase in allowable peak bundle power is needed andfuel thermal design limits will be met in the MELLLA+ domain. The analyses for each fuelreload are required to meet the criteria accepted by the NRC as specified in Reference 4 orotherwise approved in an associated TS amendment request.

In addition, future fuel designs willmeet acceptance criteria approved by the NRC.11.3.2.3 Makeup Water SourcesThe BWR design concept includes a variety of ways to pump water into the reactor vessel to dealwith all types of events. There are numerous safety-related and non-safety related cooling watersources. The safety-related cooling water sources alone can maintain core integrity for allpostulated events by providing adequate cooling water. There are high and low pressure, highand low volume, safety and non-safety grade means of delivering water to the vessel. Thesemeans include at least:" FW and Condensate Pumps" LPCS System" HPCS System" LPCI of the RHR System" RCIC System* SLS" CRD Pumps11-3 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Many of these diverse water supply means are redundant in both equipment and systems.The MELLLA+ operating domain expansion does not result in an increase or decrease in theavailable water sources, nor does it change the selection of those assumed to function in thesafety analyses. NRC-approved methods were used to evaluate the performance of the ECCSduring postulated LOCAs.11.3.2.4 Design Basis Accidents DBAs are very low probability hypothetical events whose characteristics and consequences areused in the design of the plant, so that the plant can mitigate their consequences to withinacceptable regulatory limits. For BWR licensing evaluations, capability is demonstrated forcoping with: (1) the range of hypothetical pipe break sizes in the largest recirculation, steam, andFW lines; (2) a postulated break in one of the ECCS lines; and (3) the most limiting small lines.This break range bounds the full spectrum of large and small, high and low energy line breaksand demonstrates the ability of plant systems to mitigate the accidents while accommodating asingle active equipment failure in addition to the postulated LOCA. Several of the significant licensing assessments are based on the LOCA and include:* Challenges to Fuel (ECCS Performance Analyses) in accordance with the rules andcriteria of 10 CFR 50.46 and Appendix K where the limiting criterion is the fuel PCT.* Challenges to the Containment wherein the primary criteria of merit are the maximumcontainment pressure calculated during the course of the LOCA and maximumsuppression (cooling) pool temperature for long-term cooling.* DBA Radiological Consequences calculated and compared to the criteria of10 CFR 50.67.11.3.2.5 Challenges to FuelThe evaluation of the ECCS performance is provided in Section 4.3. With MAPLHGR setdownsas indicated for low flow conditions, the PCT calculated for a LOCA from the MELLLA+domain is bounded by the licensing basis PCT that was calculated based on rated flow.However, the ECCS performance evaluation (Section 4.3) demonstrates significant margin tocriteria of 10 CFR 50.46 at the reduced flow of MELLLA+ domain. Therefore, the ECCS safetymargin is not significantly affected by MELLLA+ operating domain expansion. 11.3.2.6 Challenges to the Containment The peak values for containment pressure and temperature for events initiated in the MELLLA+domain meet design requirements and confirm the suitability of the plant for operation in theMELLLA+ domain. The containment dynamic and structural loads for events initiated in theMELLLA+ domain continue to meet design requirements. The containment pressure andtemperature remains below the design limits following any DBA. Therefore, the containment and its cooling systems are satisfactory for operation in the MELLLA+ domain.11-4 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)11.3.2.7 Design Basis Accident Radiological Consequences The magnitude of the potential radiological consequences depends on the quantity of fissionproducts released to the environment, the atmospheric dispersion

factors, and the dose exposurepathways.

The atmospheric dispersion factors and the dose exposure pathways do not change.The quantity of activity released to the environment is a function of the activity released from thecore and the transport mechanisms between the core and the effluent release point. Theradiological releases for events initiated in the MELLLA+ domain do not increase. The radiological consequences of LOCA inside containment, MSLBA, ILBA, CRDA, and FHAare bounded by the evaluation at the current licensed operating domain and need not bereevaluated for the MELLLA+ domain. The radiological results for all accidents remain belowthe applicable regulatory limits for the plant.11.3.2.8 Anticipated Operational Occurrence AnalysesAOOs are evaluated to demonstrate consequences that meet the SLMCPR. The SLMCPR isdetermined using NRC-approved methods. The limiting transients are core specific and areanalyzed for each reload fuel cycle to meet the licensing acceptance criteria (Section 2.2.1).Therefore, the margin of safety to the SLMCPR is not affected by operation in the MELLLA+domain.11.3.2.9 Combined EffectsDBAs are postulated using deterministic regulatory criteria to evaluate challenges to the fuel,containment, and off-site radiation dose limits. The off-site dose evaluation performed inaccordance with RG 1.3 (Reference

55) and Standard Review Plan (SRP) 15.6.5 calculates moresevere radiological consequences than the combined effects of bounding DBAs that produce thegreatest challenge to the fuel and containment.

In contrast, the DBA that produces the highestPCT does not result in damage to the fuel equivalent to the assumptions used in the off-site doseevaluation, and the DBA that produces the maximum containment

pressure, does not result inleak rates to the atmosphere equivalent to the assumptions used in the off-site dose evaluation.

Thus, the off-site doses calculated in conformance with RG 1.3 (Reference

55) and SRP 15.6.5are conservative compared to the combined effect of the bounding DBA evaluations.

11.3.2.10 Non-LOCA Radiological Release Accidents The limiting non-LOCA events were reviewed for the effect of MELLLA+. The doseconsequences for the non-LOCA radiological release accident events are shown in Section 9.0 toremain below regulatory limits.11.3.2.11 Equipment Qualification Plant equipment and instrumentation have been evaluated against the applicable criteria. Thequalification envelope either does not change due to the MELLLA+ operating domain expansion or is bounded by the current licensed operating domain.11-5 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)11.3.2.12 Balance-of-Plant Because the power, pressure, steam and FW flow rate, and FW temperature do not change forMELLLA+ operating domain expansion, there are no significant changes to the BOPsystems/equipment. MELLLA+ may increase the moisture content in BOP MS piping andcomponents. The increased moisture content affects FAC, which is discussed in Section 10.7.2.11.3.2.13 Environmental Consequences For operation in the MELLLA+ domain, the environmental effects will be controlled to the samelimits as for the current operating power/flow map. None of the present environmental releaselimits are increased as a result of MELLLA+ operating domain expansion. As a result, it is concluded that the NMP2 MELLLA+ operating domain expansion does notconstitute an unreviewed environmental question and is eligible for categorical exclusion asprovided by 10 CFR 51.22(c)(9). 11.3.2.14 Technical Specifications ChangesThe TS ensure that plant and system performance parameters are maintained within the valuesassumed in the safety analyses. The TS setpoints, AVs, operating limits, and the like are selectedsuch that the equipment parameter values are equal to or more conservative than the values usedin the safety analyses. NMP2 TS changes are provided in the NMPNS MELLLA+ LAR.Instrument uncertainties were properly considered for the setpoint changes associated withMELLLA+ operating domain expansion. The TS also address equipment operability (availability) and put limits on EOOS (not available for use) times such that the plant can be expected to have the complement of equipment available to mitigate abnormal plant events assumed in the safety analyses. Because the safety analysesfor the MELLLA+ operating domain expansion show that the results are within regulatory limits,there is no undue risk to public health and safety.The implementation of MELLLA+ requires revision of a limited number of the NMP2 TS,including a prohibition on the intentional operation with only a single recirculation loop inoperation while in the MELLLA+ operating domain as defined in the COLR. In addition, changes to the NMP2 TS are required to incorporate the DSS-CD stability solution option andchanges to the SLS (including increasing the boron-10 isotopic enrichment in the sodiumpentaborate

solution, decreasing the minimum net volume stored in the SLS tank, and increasing the SLS pump discharge pressure requirements).

TS changes will provide a level of protection comparable to previously issued TS.11.3.2.15 Assessment of 10 CFR 50.92 CriteriaThe assessment of significant hazards consideration is included in the NMPNS MELLLA+ LAR.11.3.3 Discussion of DSS-CD Stability Solution IssuesFor the NMP2 MELLLA+ operating domain expansion, the long-term stability solution is beingchanged from the currently approved Option III solution to DSS-CD. The DSS-CD solutionalgorithm, licensing basis, and application procedures are generically described in11-6 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)NEDC-33075P (Reference

2) and NEDE-33147P-A (Reference 12), and are applicable to NMP2including any limitations and conditions associated with their use and approval.

The DSS-CD solution is designed to identify the power oscillation upon inception and initiatecontrol rod insertion to terminate the oscillations prior to any significant amplitude growth.DSS-CD provides protection against violation of the SLMCPR for anticipated oscillations. DSS-CD is based on the same hardware design as Option III. However, it introduces anenhanced detection algorithm that detects the inception of power oscillations and generates anearlier power suppression trip signal exclusively based on successive period confirmation recognition. The existing Option III algorithms are retained (with generic setpoints) to providedefense-in-depth protection for unanticipated reactor instability events.11.3.4 Discussion of SLS ChangesThe SLS is described in Section 9.3.5 of the NMP2 USAR. The system provides a backupcapability for shutting down the reactor. The SLS is needed only in the event that sufficient control rods cannot be inserted into the reactor core to accomplish shutdown and cooldown in thenormal manner. To accomplish this function, the SLS injects a sodium pentaborate solution intothe reactor.The specified neutron absorber solution is sodium pentaborate. It is prepared by dissolving granularly-enriched sodium pentaborate in demineralized water (NMP2 USAR Section 9.3.5.2). The boron absorbs thermal neutrons and thereby terminates the nuclear fission chain reaction inthe uranium fuel. The sodium pentaborate also acts as a buffer to maintain the pool pH at orabove 7.0 to prevent the re-evolution of iodine, when mixed in the suppression pool following aLOCA accompanied by significant fuel damage (NMP2 USAR Section 9.3.5.1). The NMPNS MELLLA+ LAR contains an evaluation utilizing a method provided inNRC-approved LTR NEDE-31096P-A (Reference

56) that demonstrates the boron equivalency requirement of 10 CFR 50.62(c)(4) is met, when the changes to the SLS flow rate and theboron-10 isotope enrichment are included.

In the event of a single SLS pump failure during apostulated ATWS, a single SLS pump will be capable of injecting sufficient negative reactivity, thereby increasing safety margin.The proposed boron-10 enrichment changes do not affect the capability to achieve and maintaina pH above 7.0 in the suppression pool following a LOCA, because the chemical properties andconcentration of the sodium pentaborate solution injected into the suppression pool will remainthe same. Given the reduced volume of solution that will be available, there will be a two hourreduction in the time available to add boron to the suppression pool to maintain the pH above 7.0(the nominal time based on a low level alarm is within 22 hours versus the current requirement of within 24 hours). The 22 hours remains within the guideline of less than 24 hours with a largemargin to the minimum requirements for a manual operator action of 30 minutes.11-7 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)

12.0 REFERENCES

1. GE Hitachi Nuclear Energy, "General Electric Boiling Water Reactor MaximumExtended Load Line Limit Analysis Plus," NEDC-33006P-A, Revision 3, June 2009.2. GE Hitachi Nuclear Energy, "GE Hitachi Boiling Water Reactor Detect and SuppressSolution

-Confirmation Density," NEDC-33075P, Revision 7, June 2011; and AnthonyJ. Mendiola (NRC) to Jerald G. Head (GEH), "Revised Draft Safety Evaluation for GE-Hitachi Nuclear Energy Americas, LLC Topical Report NEDC-33075P, Revision 7, 'GEHitachi Boiling Water Reactor Detect and Suppress Solution -Confirmation Density'(TAC No. ME6577)," MFN-13-045, August 6, 2013.3. a. GE Hitachi Nuclear Energy, "Applicability of GE Methods to Expanded Operating Domains," NEDC-33173P-A, Revision 4, November 2012.b. Letter, Richard E. Kingston (GEH) to NRC, "Clarification of Stability Evaluations-NEDC-33173P," MFN 08-541, June 25, 2008.c. Letter, James F. Harrison (GEH) to NRC, "Implementation of MethodsLimitations-NEDC-33173P," MFN 08-693, September 18, 2008.d. Letter, James F. Harrison (GEH) to NRC, "NEDC-33173P -Implementation ofLimitation 12," MFN 09-143, February 27, 2009.e. GE Hitachi Nuclear Energy, "Implementation of PRIME Models and Data inDownstream Methods," NEDO-33173 Supplement 4-A, Revision 1, November 2012.4. GE Hitachi Nuclear Energy, "General Electric Standard Application for Reactor Fuel,"NEDE-2401 1-P-A- 19 and NEDE-2401 1-P-A- 19-US, May 2012.5. GE Nuclear Energy, "Generic Guidelines for General Electric Boiling Water ReactorExtended Power Uprate," NEDC-32424P-A, February 1999.6. GE Nuclear Energy, "Generic Evaluations of General Electric Boiling Water ReactorExtended Power Uprate," NEDC-32523P-A, February 2000, Supplement 1, Volume I,February 1999, and Supplement 1, Volume II, April, 1999.7. GE Nuclear Energy, "Constant Pressure Power Uprate," NEDC-33004P-A, Revision 4,July 2003.8. GE Nuclear Energy, "The GE Pressure Suppression Containment System Analytical Model," NEDM- 10320, March 1971.9. NUREG-0808, U.S. Nuclear Regulatory Commission, "Mark II Containment ProgramLoad Evaluation and Acceptance Criteria," August 1981.10. GE Nuclear Energy, "General Electric Model for LOCA Analysis in Accordance with10 CFR 50 Appendix K," NEDE-20566-P-A, Revision 2, September 1986.12-1 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)11. GE Nuclear Energy, "Qualification of the One-Dimensional Core Transient Model(ODYN) for Boiling Water Reactors (Supplement 1 -Volume 4)," NEDC-24154P-A, Revision 1, Supplement 1, February 2000.12. GE Hitachi Nuclear Energy, "DSS-CD TRACG Application," NEDE-33147P-A, Revision 4, August 2013.13. Letter, Thomas Lynch (NMPNS) to Document Control Desk (NRC), "Nine Mile PointNuclear Station Unit No. 2: Docket No. 50-410, Supplemental Information Regarding Nine Mile Point Nuclear Station, Unit No. 2 -Re: The License Amendment Request forExtended Power Uprate Operation (TAC No. ME1476) -Update to License Amendment Request," October 8, 2010.14. Letter, NRC to Ken Langdon (NMPNS), "Nine Mile Point Nuclear Station, Unit No. 2 -Issuance of Amendment Re: Extended Power Uprate (TAC No. ME1476)," December 22, 2011.15. Global Nuclear Fuel, "The PRIME Model for Analysis of Fuel Rod Thermal-Mechanical Performance," NEDC-33256P-A, NEDC-33257P-A and NEDC-33258P-A, Revision 1,September 2010.16. GE Nuclear Energy, "General Electric Methodology for Reactor Pressure Vessel FastNeutron Flux Evaluations," NEDC-32983P-A, Revision 2, January 2006.17. Regulatory Guide 1.190, "Calculational and Dosimetry Methods for Determining Pressure Vessel Neutron Fluence," U.S. NRC, March 2001.18. NRC Generic Letter 88-01, "NRC Position on IGSCC in BWR Austenitic Stainless SteelPiping," January 25, 1988.19. "Revised Risk-Informed In-Service Inspection Evaluation Procedure," EPRI TR-1 12657,Revision B, W03230, Final Report, July 1999.20. Nuclear Regulatory Commission, "Technical Report on Material Selection andProcessing Guidelines for BWR Coolant Pressure Boundary Piping," NUREG-0313, Revision 2, January 1988.21. BWRVIP-75, "BWR Vessel and Internals Project Technical Basis for Revisions toGeneric Letter 88-01 Inspection Schedules," October 1999.22. American National Standards Institute, ANSI B31.1-1977, including 1978 WinterAddenda, "Power Piping."23. GE Hitachi Nuclear Energy, "Safety Analysis Report for Nine Mile Point Nuclear StationUnit 2 Constant Pressure Power Uprate," NEDC-33351 P, Revision 0, May 2009.24. GE Nuclear Energy, "Mark II Containment Dynamic Forcing Functions Information Report," NEDO-21061, Revision 4, November 1981.12-2 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)25. NUREG-0487, U.S. Nuclear Regulatory Commission, "Mark II Containment Lead PlantProgram Load Evaluation and Acceptance Criteria," October 1978, Supplement 1,September 1980, and Supplement 2, February 1981.26. Section 6A.4 of the NMP2 USAR.27. NRC Generic Letter 89-10, "Safety-Related Motor-Operated Valve Testing andSurveillance," June 28, 1989.28. NRC Generic Letter 89-16, "Installation of a Hardened Wetwell Vent," September 1,1989.29. NRC Generic Letter 95-07, "Pressure Locking and Thermal Binding of Safety-Related Power-Operated Gate Valves," August 17, 1995.30. NRC Generic Letter 96-06, "Assurance of Equipment Operability and Containment Integrity During Design-Basis Accident Conditions," September 30, 1996.31. Letter, Sam Belcher (NMPNS) to Document Control Desk (NRC), "Nine Mile PointNuclear Station Unit No. 2; Docket No. 50-410, Response to Request for Additional Information Regarding Nine Mile Point Nuclear Station, Unit No. 2- Re: The LicenseAmendment Request for Extended Power Uprate Operation (TAC No. ME1476) -Containment Accident

Pressure, Combustible Gas Control, Pipe Stress Analysis, andBoral Monitoring Program,"

May 9, 2011.32. Regulatory Guide 1.1, "Net Positive Suction Head for Emergency Core Cooling andContainment Heat Removal System Pumps," U.S. NRC, November 2, 1970.33. GE Nuclear Energy, "Compilation of Improvements to GENE's SAFER ECCS-LOCA Evaluation Model," NEDC-32950P, Revision 1, July 2007.34. GE Nuclear Energy, "GESTR-LOCA and SAFER Models for Evaluation ofLoss-of-Coolant Accident Volume III, Supplement 1, Additional Information for UpperBound PCT Calculation," NEDE-23785P-A, Volume III, Supplement 1, Revision 1,March 2002.35. GE Nuclear Energy, "General Electric Instrument Setpoint Methodology," NEDC-31336P-A, September 1996.36. NRC Regulatory Issue Summary 2006-17, "NRC Staff Position on the Requirements of10 CFR 50.36, 'Technical Specifications,' Regarding Limiting Safety System SettingsDuring Periodic Testing and Calibration of Instrument Channels," August 24, 2006.37. Letter, Technical Specifications Task Force (TSTF) to NRC, "Transmittal of RevisedTSTF-493 Revision 4," TSTF-09-29, dated January 5, 2010; and Letter, TSTF to NRC,"Transmittal of TSTF-493 Revision 4, Errata," TSTF- 10-07, dated April 23, 2010.38. GE Nuclear Energy, "Assessment of BWR Mitigation of ATWS, Volume II(NUREG-0460 Alternate No. 3)," NEDE-24222, December 1979.12-3 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)39. GE Nuclear Energy, "ATWS Rule Issues Relative to BWR Core Thermal-Hydraulic Stability," NEDO-32047-A, June 1995, (SER includes approval for: "Mitigation of BWRCore Thermal-Hydraulic Instabilities in ATWS," NEDO-32164, December 1992.).40. GE Nuclear Energy, "Mitigation of BWR Core Thermal-Hydraulic Instabilities inATWS," NEDO-32164, December 1992.41. GE Hitachi Nuclear Energy, "Migration to TRACG04 / PANAC 11 from TRACG02 /PANACIO for TRACG AOO and ATWS Overpressure Transients," NEDE-32906P, Supplement 3-A, Revision 1, April 2010.42. Letter from James F. Harrison (GEH) to NRC, "Use of the Shumway Tmin Correlation with Zircaloy for TRACG Analyses," MFN 13-073, September 9, 2013.43. Regulatory Guide 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis," U.S. NRC,Revision 2, May 2011.44. Regulatory Guide 1.200, "An Approach for Determining the Technical Adequacy ofProbabilistic Risk Assessment Results for Risk-Informed Activities," U.S. NRC,Revision 2, March 2009.45. Letter, Richard V. Guzman (NRC) to Kenneth Langdon (NMPNS), "Nine Mile PointNuclear Station, Unit No. 2 -Issuance of Amendment Regarding Extension ofCompletion Time for an Inoperable Division 1 or Division 2 Diesel Generator (TACNo. ME3736)," October 31, 2011.46. "BWR Core Shroud Inspection and Flaw Evaluation Guidelines," BWRVIP-76, EPRITR- 114232, November 1999.47. BWRVIP-47, "BWR Lower Plenum Inspection and Flaw Evaluation Guidelines," November 2004.48. BWRVIP-25, "BWR Core Plate Inspection and Flaw Evaluation Guidelines," December 1996.49. BWRVIP-26, "BWR Top Guide Inspection and Flaw Evaluation Guidelines," November 2004.50. BWRVIP-06-A, "Safety Assessment of BWR Reactor Internals," March 2002.51. NRC Generic Letter 94-03, "Intergranular Stress Corrosion Cracking of Core Shrouds inBoiling Water Reactors," July 25, 1994.52. BWRVIP-183, "Top Guide Grid Beam Inspection and Flaw Evaluation Guidelines," December 2007.53. GE Hitachi Nuclear Energy Safety Communication, "Standby Liquid Control SystemDilution Flow," SC 10-13, October 11, 2010.54. Regulatory Guide 1.49, "Power Levels of Nuclear Power Plants," U.S. NRC, Revision 1,December 1973 (Withdrawn July 2007).12-4 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)55. Regulatory Guide 1.3, "Assumptions Used for Evaluating the Potential Radiological Consequences of a Loss of Coolant Accident for Boiling Water Reactors," U.S. NRC,Revision 2, June 1974.56. GE Nuclear Energy, "Anticipated Transients Without Scram Response to NRC ATWSRule, 1OCFR50.62," NEDE-31096P-A, February 1987.57. Regulatory Guide 1.99, "Radiation Embrittlement of Reactor Vessel Materials," U.S.NRC, Revision 2, May 1988.58. GE Hitachi Nuclear Energy, "General Electric Boiling Water Reactor Detect andSuppress Solution-Confirmation Density," NEDC-33075P-A, Revision 6, January 2008.12-5 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Appendix ADisposition of additional limitations and conditions related to the final SE forNEDC-33173P, "Applicability of GE Methods to Expanded Operating Domains"There are 24 limitations and conditions listed in Section 9 of the Methods LTR SER. The tablebelow lists each of the 24 limitations and conditions. The table also shows that NMP2 complieswith 14 of the limitations and conditions. The table identifies which section of this M+SARdiscusses compliance with each limitation and condition. Ten limitations and conditions are notapplicable to NMP2 for the following reasons.9.2 NMP2 MELLLA+ based on TGBLA06/PANACl1, not TGBLA04/PANAC 10.9.4 This penalty is specific for EPU applications. Limitation and Condition 9.5 addresses MELLLA+ SLMCPR penalty.9.13 NMP2 MELLLA+ is less than 10 weight percent Gd.9.14 NMP2 MELLLA+ has a PRIME T-M and PRIME fuel temperature basis.9.15 NMP2 MELLLA+ licensing basis is not based on TRACG for the voidreactivity coefficient bias and uncertainties relative to lattice designs.9.16 NMP2 MELLLA+ licensing basis is not based on TRACG for the voidcoefficient biases and uncertainties for known dependencies. 9.18 Stability Setpoints Adjustment to DSS-CD because the significant conservatisms in the current licensing methodology and associated MCPRmargins are more than sufficient to compensate for the overall uncertainty in the OPRM instrumentation. 9.20 NMP2 MELLLA+ licensing basis is not based on TRACG for the Void-Quality Correlation. 9.21 NMP2 MELLLA+ is not based on a mixed core.9.22 NMP2 MELLLA+ is not based on unapproved fuel product lines.There is one remaining limitation and condition, Limitation and Condition 9.23 that relates toMELLLA+ eigenvalue tracking. If NMP2 is the first implementation of MELLLA+, then NMP2intends to comply with that limitation and condition. The required data will be collected andevaluated in accordance with Limitation and Condition 9.23. This information will be submitted to the NRC in accordance with the limitation and condition following the implementation of theMELLLA+ expanded operating domain at NMP2.Note that Reference 3.c clarifies the implementation of Limitations and Conditions 9.3, 9.8, 9.17,and 9.19.A-I NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Appendix A (continued) Disposition of additional limitations and conditions related to the final SE forNEDC-33173P, "Applicability of GE Methods to Expanded Operating Domains"Limitation Section of NMP2and M+SAR whichCondition Limitation andM+A whcNubrCondition Lmtion Te Limitation and Condition Description Disposition addresses theNumber Condition Title Lmtto nfrom NRC Limitation andSER Condition The neutronic methods used to simulate thereactor core response and that feed into theTGBLA/PANAC downstream safety analyses supporting Comply Table 1-1 and9.1 Version operation at EPU/MELLLA+ will apply Section 2.6.1TGBLA06/PANAC 11 or later NRC-approved version of neutronic method.For EPU/MELLLA+ applications, relying onTGBLA04/PANAC 10 methods, the bundleRMS difference uncertainty will be established from plant-specific core-tracking data, based Table 1-19.2 3D Monicore on TGBLA04/PANACI0. The use of plant- N/Aspecific trendline based on the neutronic (1)method employed will capture the actualbundle power uncertainty of the coremonitoring system.A-2 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Limitation Section of NMP2and M+SAR whichCondition Limitation andM+A whhNubrCondition Lmtion Te Limitation and Condition Description Disposition addresses theNumber Condition Title Lmtto nfrom NRC Limitation andSER Condition Plant-specific EPU and expanded operating domain applications will confirm that the corethermal power to core flow ratio will not Sections 1.2.1 and 2.2.5exceed 50 MWt/Mlbrn/hr at any statepoint in93 Power/Flow the allowed operating domain. For plants that Comply (2)Ratio exceed the power-to-flow value of50 MWtiMlbm/hr, the application will provide Consistent withpower distribution assessment to establish that Reference 3.cneutronic methods axial and nodal powerdistribution uncertainties have not increased. For EPU operation, a 0.02 value shall be added9.4 SLMCPR 1 to the cycle-specific SLMCPR value. Thisadder is applicable to SLO, which is derived N/A (3)from the dual loop SLMCPR value.This Limitation has been revised according toAppendix I of this SE.For operation at MELLLA+, including operation at the EPU power levels at the9.5 SLMCPR 2 achievable CF statepoint, a 0.01 value shall be Comply Sections 2.2.1 and 2.2.5added to the cycle-specific SLMCPR value forpower-to-flow ratios up to 42 MWt/Mlbm/hr, and a 0.02 value shall be added to the cycle-specific SLMCPR value for power-to-flow ratios above 42 MWt/Mlbm/hr. A-3 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Limitation Section of NMP2and M+SAR whichCondition Limitation andNubrCondition Lmtion Te Limitation and Condition Description Disposition addresses theNumber Condition Title Lmtto nfrom NRC Limitation andSER Condition The plant specific R-factor calculation at abundle level will be consistent with latticeaxial void conditions expected for the hot9.6 R-Factor channel operating state. The plant-specific Comply Section 2.2EPU/MELLLA+ application will confirm thatthe R-factor calculation is consistent with thehot channel axial void conditions. For applications requesting implementation ofEPU or expanded operating domains,including MELLLA+, the small and largebreak ECCS-LOCA analyses will include top-peaked and mid-peaked power shape in9.7 ECCS-LOCA 1 establishing the MAPLHGR and determining Comply Sections 4.3.2 and 4.3.3the PCT. This limitation is applicable to boththe licensing bases PCT and the upper boundPCT. The plant-specific applications willreport the limiting small and large breaklicensing basis and upper bound PCTs.A-4 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Limitation Section of NMP2and M+SAR whichCondition Limitation andMSA whcNubrCondition Lmtion Te Limitation and Condition Description Disposition addresses theNumber Condition Title Lmtto nfrom NRC Limitation andSER Condition The ECCS-LOCA will be performed for allstatepoints in the upper boundary of theexpanded operating domain, including theminimum CF statepoints, the transition Section 4.3.3statepoint, as defined in Reference 1 and the9.8 ECCS-LOCA 2 55 percent CF statepoint. The plant-specific Comply (2)application will report the limitingECCS-LOCA results as well as the rated Consistent withpower and flow results. The SRLR will Reference 3.cinclude both the limiting statepoint ECCS-LOCA results and the rated conditions ECCS-LOCA results.Plant-specific EPU and MELLLA+applications will demonstrate and documentthat during normal operation and core-wide AOOs, the T-M acceptance criteria asspecified in Amendment 22 to GESTAR II willbe met. Specifically, during an AOO, the9.9 Transient LHGR licensing application will demonstrate that the: Comply Section 9.1.11 (1) loss of fuel rod mechanical integrity willnot occur due to fuel melting and (2) loss offuel rod mechanical integrity will not occurdue to pellet-cladding mechanical interaction. The plant-specific application will demonstrate that the T-M acceptance criteria are met for theboth the U02and the limiting GdO2rods.A-5 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Limitation and Section of NMP2Condition Limitation and M+SAR whichNumber Condition Title Limitation and Condition Description Disposition addresses thefrom NRC Limitation andSER Condition Each EPU and MELLLA+ fuel reload willdocument the calculation results of theTransient LHGR analyses demonstrating compliance to9.10 transient T-M acceptance criteria. The plant Comply Section 9.1.1T-M response will be provided with the SRLRor COLR, or it will be reported directly to theNRC as an attachment to the SRLR or COLR.To account for the effect of the void historybias, plant-specific EPU and MELLLA+applications using either TRACG or ODYNwill demonstrate an equivalent to 10 percentmargin to the fuel centerline melt and the1 percent cladding circumferential plasticstrain acceptance criteria due to pellet-cladding mechanical interaction for all ofTransient LHGR limiting AOO transient events, including 9.11 3 EOOS. Limiting transients in this case, refers Comply Section 9.1.1to transients where the void reactivity coefficient plays a significant role (such aspressurization events). If the void history biasis incorporated into the transient model withinthe code, then the additional 10 percent marginto the fuel centerline melt and the 1 percentcladding circumferential plastic strain is nolonger required. A-6 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Limitation Section of NMIP2and M+SAR whichCondition Limitation andNumber Condition Title Limitation and Condition Description Disposition addresses thefombR C o o TLimitation andfrom NRC Condition SERIn MFN 06-481, GE committed to submitplenum fission gas and fuel exposure gammascans as part of the revision to the T-Mlicensing process. The conclusions of theplenum fission gas and fuel exposure gammascans of GE 1Oxl 0 fuel designs as operatedwill be submitted for NRC staff review andLHGR and approval. This revision will be accomplished Section 2.6.39.12 Exposure through Amendment to GESTAR II or in a ComplyQualification T-M licensing LTR. PRIME (a newly (4)developed T-M code) has been submitted tothe NRC staff for review (Reference 15).Once the PRIME LTR and its application areapproved, future license applications for EPUand MELLLA+ referencing LTRNEDC-33173P must utilize the PRIME T-Mmethods.Before applying 10 weight percent Gd tolicensing applications, including EPU andexpanded operating domain, the NRC staffApplication of needs to review and approve the T-M LTR Section 2.09.13 10 Weight demonstrating that the T-M acceptance criteria N/APercent Gd specified in GESTAR II and Amendment 22 to (5)GESTAR II can be met for steady-state andtransient conditions. Specifically, the T-Mapplication must demonstrate that the T-Macceptance criteria can be met for thermalA-7 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Limitation Section of NMP2and M+SAR whichCondition Limitation andNumber Condition Title Limitation and Condition Description Disposition addresses thefombR C o o TLimitation andfrom NRC Condition SER IIoverpower (TOP) and mechanical overpower (MOP) conditions that bounds the response ofplants operating at EPU and expandedoperating domains at the most limitingstatepoints, considering the operating flexibilities (e.g., EOOS).Before the use of 10 weight percent Gd formodem fuel designs, NRC must review andapprove TGBLA06 qualification submittal. Where a fuel design refers to a design withGd-bearing rods adjacent to vanished or waterrods, the submittal should include specificinformation regarding acceptance criteria forthe qualification and address any downstream effects in terms of the safety analysis. The10 weight percent Gd qualifications submittal can supolement this report.Any conclusions drawn from the NRC staffPart 21 evaluation of the GE's Part 21 report will beEvaluation of applicable to the GESTR-M T-M assessment 9.14 GESTR-M Fuel of this SE for future license application. GE N/A (6)submitted the T-M Part 21 evaluation, which isCalculation currently under NRC staff review. Uponcompletion of its review, NRC staff willinform GE of its conclusions. A-8 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Limitation Section of NMP2and M+SAR whichCondition Limitation andM+A whhNubrCondition Lmtion Te Limitation and Condition Description Disposition addresses theNumber Condition Title Lmtto nfrom NRC Limitation andSER Condition The void reactivity coefficient bias and Section 2.29.15 Void Reactivity uncertainties in TRACG for EPU and N/A1 MELLLA+ must be representative of the (7)lattice designs of the fuel loaded in the core.A supplement to TRACG /PANAC 1I forAOO is under NRC staff review(Reference 41). TRACG internally models theresponse surface for the void coefficient biasesand uncertainties for known dependencies dueto the relative moderator density and exposureon nodal basis. Therefore, the void historybias determined through the methods reviewcan be incorporated into the response surface"known" bias or through changes in latticeVoid Reactivity physics/core simulator methods for9.16 2 establishing the instantaneous cross-sections. N/A (7)Including the bias in the calculations negatesthe need for ensuring that plant-specific applications show sufficient margin. Forapplication of TRACG to EPU and MELLLA+applications, the TRACG methodology mustincorporate the void history bias. The mannerin which this void history bias is accounted forwill be established by the NRC staff SEapproving NEDE-32906P, Supplement 3,"Migration to TRACG04/PANAC 11 fromTRACG02/PANAC 10," May 2006A-9 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Limitation Section of NMP2and M+SAR whichCondition Limitation and Limitation and Condition Description Disposition addresses theNumber Condition Title Limitation andfrom NRC Condition SER Condition (Reference 41). This limitation applies untilthe new TRACG/PANAC methodology isapproved by the NRC staff.The instrumentation specification design baseslimit the presence of bypass voiding to5 percent (LRPM (sic) levels). Limiting thebypass voiding to less than 5 percent forlong-term steady operation ensures that Section 2.1.2instrumentation is operated within theSteady-State 5 specification. For EPU and MELLLA+9.17 Percent Bypass operation, the bypass voiding will be evaluated Comply (2)Voiding on a cycle-specific basis to confirm that thevoid fraction remains below 5 percent at all Consiste witLPRM levels when operating at steady-state conditions within the MELLLA+ upperboundary. The highest calculated bypassvoiding at any LPRM level will be providedwith the plant-specific SRLR.A-10 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Limitation Section of NMP2and M+SAR whichCondition Limitation andNumber Condition Title Limitation and Condition Description Disposition addresses theLimitation andfrom NRC Condition SER Condition The NRC staff concludes that the presencebypass voiding at the low-flow conditions where instabilities are likely can result incalibration errors of less than 5 percent forStability OPRM cells and less than 2 percent for APRM98 Stabiity signals. These calibration errors must be9.18 Setpoints accounted for while determining the setpoints N/A Section 2.4.1Adjustment for any detect and suppress long-term methodology. The calibration values for thedifferent long-term solutions are specified inthe associated sections of this SE, discussing the stability methodology. For applications involving PANCEA/ODYN/ISCOR/TASC for operation at EPU and MELLLA+, an additional 0.01will be added to the OLMCPR, until such time Sections 2.2.2 and 9.1.1that GE expands the experimental databaseVoid-Quality supporting the Findlay-Dix void-quality (2),(10)9.19 Correlation 1 correlation to demonstrate the accuracy and Complyperformance of the void-quality correlation Consistent withbased on experimental data representative of Reference 3.cthe current fuel designs and operating conditions during steady-state, transient, andaccident conditions. A-i I NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Limitation Section of NMP2and M+SAR whichCondition Limitation andM+ RwihNubrCondition Lmtion Te Limitation and Condition Description Disposition addresses theNumber Condition Title Lmtto nfrom NRC Limitation andSER Condition The NRC staff is currently reviewing Supplement 3 to NEDE-32906P, "Migration toTRACG04/PANAC1 1 fromTRACG02/PANAC 10," dated May 20060 Void-Quality (Reference 41). The adequacy of the TRACG9.20 Correlation 2 interfacial shear model qualification for N/A (7)application to EPU and MELLLA+ will beaddressed under this review. Any conclusions specified in the NRC staff SE approving Supplement 3 to LTR NEDC-32906P (Reference

41) will be applicable as approved.

Plants implementing EPU or MELLLA+ withmixed fuel vendor cores will provide plant-specific justification for extension of GE'sanalytical methods or codes. The content of Section 2.09.21 Mixed Core the plant-specific application will cover the N/AMethod 1 topics addressed in this SE as well as subjects (8)relevant to application of GE's methods tolegacy fuel. Alternatively, GE maysupplement or revise LTR NEDC-33173P (Reference

3) for mixed core application.

For any plant-specific applications ofTGBLA06 with fuel type characteristics not Section 2.09.22 Mixed Core covered in this review, GE needs to provide N/AMethod 2 assessment data similar to that provided for the (8)GE fuels. The Interim Methods review isapplicable to all GE lattices up to GEl4. FuelA-12 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Limitation Section of NMP2and M+SAR whichCondition Limitation andNumber Condition Title Limitation and Condition Description Disposition addresses thefombR C o o TLimitation andfrom NRC Condition SERlattice designs, other than GE lattices up toGE14, with the following characteristics arenot covered by this review:* square internal water channels watercrosses* Gd rods simultaneously adjacent to waterand vanished rods* 1 lxii lattices* MOX fuelThe acceptability of the modified epithermal slowing down models in TGBLA06 has notbeen demonstrated for application to these orother geometries for expanded operating domains.Significant changes in the Gd rod opticalthickness will require an evaluation of theTGBLA06 radial flux and Gd depletion modeling before being applied. Increases inthe lattice Gd loading that result in nodalreactivity biases beyond those previously established will require review before the GEmethods may be applied.MELLLA+ In the first plant-specific implementation of9.23 Eigenvalue MELLLA+, the cycle-specific eigenvalue Comply (9)Tracking tracking data will be evaluated and submitted A-13 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Limitation Section of NMP2and M+SAR whichCondition Limitation andNumber Condition Title Limitation and Condition Description Disposition addresses thefombR C o o TLimitation andfrom NRC Condition SERto NRC to establish the performance ofnuclear methods under the operation in thenew operating domain. The following datawill be analyzed:

  • Hot critical eigenvalue,
  • Cold critical eigenvalue,
  • Nodal power distribution (measured andcalculated TIP comparison),
  • Bundle power distribution (measured andcalculated TIP comparison),
  • Thermal margin,* CF and pressure drop uncertainties, and* The MCPR importance parameter (MIP)Criterion (i.e., determine if core and fueldesign selected is expected to produce aplant response outside the priorexperience base).Provision of evaluation of the core-tracking data will provide the NRC staff with bases toestablish if operation at the expandedoperating domain indicates:

(1) changes in theperformance of nuclear methods outside theEPU experience base; (2) changes in theavailable thermal margins; (3) need forchanges in the uncertainties and NRC-A-14 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Limitation Section of NMP2and M+SAR whichCondition Limitation andNumber Condition Title Limitation and Condition Description Disposition addresses thefombR C o o TLimitation andfrom NRC Condition SERapproved criterion used in the SLMCPRmethodology; or (4) any anomaly that mayrequire corrective actions.The plant-specific applications will provideprediction of key parameters for cycleexposures for operation at EPU (andMELLLA+ for MELLLA+ applications). Theplant-specific prediction of these keyparameters will be plotted against the EPUReference Plant experience base and4 Plant-Specific MELLLA+ operating experience, if available. 9.24 plant-pionc For evaluation of the margins available in the Comply Section 2.1.2Application fuel design limits, plant-specific applications will also provide quarter core map (assuming core symmetry) showing bundle power, bundleoperating LHGR, and MCPR for BOC, MOC,and EOC. Because the minimum margins tospecific limits may occur at exposures otherthan the traditional BOC, MOC, and EOC, thedata will be provided at these exposures. A-15 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Appendix A (continued) Disposition of additional limitations and conditions related to the final SE forNEDC-33173P, "Applicability of GE Methods to Expanded Operating Domains"Notes:1. As shown in Table 1-1, NMP2 used TGBLA06 and PANAC 11.2. Correspondence concerning implementation of this limitation and condition is docketed inReference 3.c.3. This limitation and condition relates to EPU applications and as such is not applicable to theM+SAR.4. The PRIME LTR and its application (Reference 3.a) was approved on January 22, 2010 andimplemented in GESTAR II in September 2010 (Reference 4). PRIME fuel parameters willbe used in all analyses requiring fuel performance parameters.

5. NMP2 uses GEl4 fuel, and as such does not seek to apply 10 wt.% Gd to this licensing application.
6. This limitation and condition relates to GEH's treatment of the NRC staff review of the10 CFR Part 21 report related to the GESTR-M T-M evaluation.

The NMP2 M+SAR has aPRIME T-M and PRIME fuel temperature basis included. Therefore, this limitation is nolonger applicable.

7. The NMP2 M+SAR licensing basis is not based on TRACG for: (1) the void reactivity coefficient bias and uncertainties relative to lattice designs; (2) the void coefficient biasesand uncertainties for known dependencies; and (3) the Void-Quality Correlation.

The NMP2M+SAR analysis uses ODYN as the licensing basis code, and as such, this limitation andcondition is not applicable to the NMP2 M+SAR.8. The NMP2 M+SAR is not based on a mixed core, nor is it based on unapproved fuel productlines. NMP2 uses GE14, therefore, this limitation and condition is not applicable to theNMP2 M+SAR.9. If NMP2 is a first plant application of MELLLA+ then GEH will provide the requiredinformation. This limitation and condition relates to a GEH commitment to submit cycle-specific eigenvalue tracking data to the NRC to establish performance of GEH methodsunder operation in the MELLLA+ operating domain. As such, this requirement specifies information to be supplied at a later date by GEH.10. In the event that the cycle specific reload analysis is based on TRACG rather than ODYN forAOO, no 0.01 adder to the OLMCPR is required. A-16 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Appendix BDisposition of additional limitations and conditions related to the final SE forNEDC-33006P, "Maximum Extended Load Line Limit Analysis Plus"There are 54 limitations and conditions listed in Section 12 of the M+LTR SER. The tablebelow lists each of the 54 limitations and conditions. The table also shows that NMP2 complieswith 47 of the limitations and conditions. The table identifies which section of this M+SARdiscusses compliance with each limitation and condition. The remaining seven limitations andconditions are not applicable to NMP2 for the following reasons.12.3d NMP2 MELLLA+ is not based on unapproved fuel product lines.12.3e NMP2 MELLLA+ is not based on unapproved fuel product lines.12.3f NMP2 MELLLA+ is not based on unapproved fuel product lines.12.1 O.c NMP2 MELLLA+ takes credit for off-rated limits at the minimum CFstatepoint. Core monitoring is required. 12.20 NMP2 MELLLA+ is based on plant specific ATWS Instability (12.19).12.23.6 NMP2 MELLLA+ is not based on unapproved fuel product lines.12.23.7 NMP2 MELLLA+ is not based on unapproved fuel product lines.B-I NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Appendix B (continued) Disposition of additional limitations and conditions related to the final SE forNEDC-33006P, "Maximum Extended Load Line Limit Analysis Plus"Limitation Section of NMP2Cnd Limitation and M+SAR whichnumber Condition Limitation and Condition Description Disposition addresses theNumberTitle Limitation andSER Condition The plant-specific application will confirm that foroperation within the boundary defined by theMELLLA+ upper boundary and maximum CFrange, the GEXL-PLUS experimental databasecovers the thermal-hydraulic conditions the fuelbundles will experience, including, bundle power,mass flux, void fraction,

pressure, and subcooling.

If the GEXL-PLUS experimental database does notcover the within bundle thermal-hydraulic conditions, during steady-state, transient conditions, 12.1 GEXL-PLUS and DBA conditions, GHNE will inform the NRC Comply Sections 1.1.3 andat the time of submittal and obtain the necessary 2.6.4data for the submittal of the plant-specific MELLLA+ application. In addition, the plant-specific application will confirm that theexperimental pressure drop database for thepressure drop correlation covers the pressure dropsanticipated in the MELLLA+ range.With subsequent fuel designs, the plant-specific applications will confirm that the databasesupporting the CPR correlations covers the powers,B-2 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Limitation Section of NMP2andCnd Limitation and M+SAR whichCondition Number Condition Limitation and Condition Description Disposition addresses thefrom NRC Title Limitation andSER Condition flows and void fractions BWR bundles willexperience for operation at and within theMELLLA+ domain, during steady-state, transient, and DBA conditions. The plant-specific submittal will also confirm that the NRC staff reviewed andapproved the associated CPR correlation if thechanges in the correlation are outside theGESTAR I1 (Amendment

22) process.

Similarly, the plant-specific application will confirm that theexperimental pressure drop database does cover therange of pressures the fuel bundles will experience for operation within the MELLLA+ domain.Plant-specific MELLLA+ applications must complywith the limitations and conditions specified in and12.2 Related LTRs be consistent with the purpose and content covered Comply Section 1.0in the NRC staff SEs approving the latest version ofthe following LTRs: NEDC-33173P, NEDC-33075P-A, and NEDC-33147-A. B-3 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Limitation Section of NMP2Cnd Limitation and M+SAR whichnumber Condition Limitation and Condition Description Disposition addresses thefrmbNr Title Limitation andSER Condition The plant-specific analyses supporting MELLLA+operation will include all operating condition changes that are implemented at the plant at thetime of MELLLA+ implementation. Operating condition changes include, but are not limited to,those changes that affect, an increase in the domepressure, maximum CF, fuel cycle length, or anyConcurrent changes in the licensed operational enhancements. Comply Section 1.1.2Changes For example, with an increase in dome pressure, thefollowing analyses must be analyzed: the ATWSanalysis, the ASME overpressure

analyses, thetransient
analyses, and the ECCS-LOCA analysis.

Any changes to the safety system settings or anyactuation setpoint changes necessary to operatewith the increased dome pressure must be includedin the evaluations (e.g., SRV setpoints). B-4 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Limitation Section of NMP2Cnd Limitation and M+SAR whichnumber Condition Limitation and Condition Description Disposition addresses thefrmbNr Title Limitation andfrom NRC Condition SERFor all topics in LTR NEDC-33006P that arereduced in scope or generically dispositioned, theplant-specific application will provide justification that the reduced scope or generic disposition isapplicable to the plant. If changes that invalidate 12.3.b the LTR dispositions are to be implemented at the Comply Section 1.1 1time of MELLLA+ implementation, theplant-specific application will provide analyses andevaluations that demonstrate the cumulative effectwith MELLLA+ operation. For example, if thedome pressure is increased, the ECCS performance will be evaluated on a plant-specific basis.Any generic bounding sensitivity analyses providedin LTR NEDC-33006P will be evaluated to ensurethat the key plant-specific input parameters andassumptions are applicable and bounded. If thesegeneric sensitivity analyses are not applicable oradditional operating condition changes affect the12.3.c generic sensitivity

analyses, a plant-specific Comply Section 1.1.1evaluation will be provided.

For example, with anincrease in the dome pressure, the ATWSsensitivity analyses that model operator actions(e.g., depressurization if the HCTL is reached)needs to be reanalyzed, using the bounding domepressure condition. B-5 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Limitation and Section of NMP2Cnd Limitation and M+SAR whichnumber Condition Limitation and Condition Description Disposition addresses thefrmbNr Title Limitation andSER Condition 12.3.dIf a new GE fuel product line or another vendor'sfuel is loaded at the plant, the applicability of anygeneric sensitivity analyses supporting theMELLLA+ application shall be justified in theplant-specific application. If the generic sensitivity analyses cannot be demonstrated to be applicable, the analyses will be performed including the newfuel. For example, the ATWS instability analysessupporting the MELLLA+ condition are based onthe GEl4 fuel response. New analyses thatdemonstrate the ATWS instability performance ofthe new GE fuel or another vendor's fuel forMELLLA+ operation shall be provided to supportthe plant-specific application. N/ASection 2.0(1)12.3.eIf a new GE fuel product line or another vendor'sfuel is loaded at the plant prior to a MELLLA+application, the analyses supporting the plant-specific MELLLA+ application will be based on aspecific core configuration or bounding coreconditions. Any topics that are generically dispositioned or reduced in scope in LTRNEDC-33006P will be demonstrated to beapplicable, or new analyses based on the specificcore configuration or bounding core conditions willbe provided. N/ASection 2.0(1)B-6 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Limitation Section of NMP2and Limitation and M+SAR whichCondition Condition Limitation and Condition Description Disposition addresses theNumberfrmbNr Title Limitation andfrom NRC Condition SERIf a new GE fuel product line or another vendor'sfuel is loaded at the plant prior to a MELLLA+application, the plant-specific application willreference an NRC-approved stability methodsupporting MELLLA+ operation, or provide Section 2.012.3.f sufficient plant-specific information to allow the N/ANRC staff to review and approve the stability (1)method supporting MELLLA+ operation. Theplant-specific application will demonstrate that theanalyses and evaluations supporting the stability method are applicable to the fuel loaded in the core.For MELLLA+ operation, core instability ispossible in the event a transient or plant maneuverplaces the reactor at a high power/low-flow condition. Therefore, plants operating atMELLLA+ conditions must have a NRC-approved 12.3.g instability protection method. In the event theinstability protection method is inoperable, the Comply Section 2.4applicant must employ an NRC-approved backupinstability method. The licensee will provide TSchanges that specify the instability methodoperability requirements for MELLLA+ operation, including any BSP methods.The plant-specific MELLLA+ application shall12.4 Reload analysis provide the plant-specific thermal limits assessment Comply Sections 1.1.1 andsubmittal and transient analysis results. Considering the 9.1.1timing requirements to support the reload, the fuelB-7 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Limitation Section of NMP2andCnd Limitation and M+SAR whichnumber Condition Limitation and Condition Description Disposition addresses theNumberfrom NRC Title Limitation andSER Condition and cycle-dependent analyses including the plant-specific thermal limits assessment may besubmitted by supplementing the initial M+SAR.Additionally, the SRLR for the initial MELLLA+implementation cycle shall be submitted for NRCstaff confirmation. The licensee will amend the TS LCO for any EOOS Sections 1.1.1 and12.5.a (i.e., SLO) or operating flexibilities prohibited in Comply 1.2.4the plant-specific MELLLA+ application. For an operating flexibility, such as Feedwater Heater(s) Out-of-Service (FWHOOS), that is12.5.b prohibited in the MELLLA+ plant-specific application but is not included in the TS LCO, the Comply Section 1.2.4licensee will propose and implement a licenseOperating condition. Flexibility The power flow map is not specified in the TS;however, it is an important licensed operating domain. Licensees may elect to be licensed andoperate the plant under plant-specific-expanded 12.5.c domain that is bounded by the MELLLA+ upper Comply Section 1.2.1boundary. Plant-specific applications approved foroperation within the MELLLA+ domain willinclude the plant-specific power/flow mapspecifying the licensed domain in the COLR.SLMCPR Until such time when the SLMCPR methodology 12.6 Statepoints and (References 10 and 25) for off-rated SLMCPR Comply Section 2.2.1CF Uncertainty calculation is approved by the staff for MELLLA+B-8 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Limitation Section of NMP2andCnd Limitation and M+SAR whichnumber Condition Limitation and Condition Description Disposition addresses thefrmbNr Title Limitation andfrom NRC Condition SERoperation, the SLMCPR will be calculated at therated statepoint (120 percent P/100 percent CF), theplant-specific minimum CF statepoint (e.g., 120 percent P /80 percent CF), and at the100 percent OLTP at 55 percent CF statepoint. Thecurrently approved off-rated CF uncertainty will beused for the minimum CF and 55 percent CFstatepoints. The uncertainty must be consistent with the CF uncertainty currently applied to theSLO operation or as NRC-approved for MELLLA+operation. The calculated values will bedocumented in the SRLR.Manual operator actions are not adequate to controlthe consequences of instabilities when operating inthe MELLLA+ domain. If the primary stability protection system is declared inoperable, a non-12.7 Stability manual NRC-approved backup protection system Comply Section 2.4must be provided, or the reactor core must beoperated below a NRC-approved backup stability boundary specifically approved for MELLLA+operation for the stability option employed. B-9 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Limitation Section of NMP2andCnd Limitation and M+SAR whichnumber Condition Limitation and Condition Description Disposition addresses thefrmbNr Title Limitation andSER Condition The applicant is to provide a plant-specific Fluence evaluation of the MELLLA+ RPV fluence using the8 Methodology most up-to-date NRC-approved fluence12.8 and Fracture methodology. This fluence will then be used to Comply Section 3.2.1Toughness provide a plant-specific evaluation of the RPVfracture toughness in accordance with RG 1.99,Revision 2 (Reference 57).MELLLA+ applicants must identify all other thanReactor Category "A" materials, as defined in12.9 Coolant NUREG-0313 (Reference 20), Revision 2, thatPressure exist in its RCPB piping, and discuss the adequacy Comply Section 3.5.1.4Boundary of the augmented inspection programs in light ofthe MELLLA+ operation on a plant-specific basis.B-10 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Limitation Section of NMIP2andCnd Limitation and M+SAR whichnumber Condition Limitation and Condition Description Disposition addresses thefrmbNr Title Limitation andfrom NRC Condition SERThe plant-specific application will provide the10 CFR Part 50, Appendix K, and the nominalPCTs calculated at the rated EPU power/rated CF,rated EPU power/minimum CF, at the low-flowMELLLA+ boundary (Transition Statepoint). Forthe limiting statepoint, both the upper bound andthe licensing PCT will be reported. The M+SARwill justify why the transition statepoint ECCO -Ca ECCS-LOCA response bounds the 55 percent CF Comply Section 4.3.212.10.a Off-rated statepoint. The M+SAR will provide discussion onMultiplier what power/flow combination scoping calculations were performed to identify the limiting statepoints in terms of DBA-LOCA PCT response for theoperation within the MELLLA+ boundary. TheM+SAR will justify that the upper bound andlicensing basis PCT provided is in fact the limitingPCT considering uncertainty applications to thenon-limiting statepoints. B-il NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Limitation Section of NMP2andCnd Limitation and M+SAR whichnumber Condition Limitation and Condition Description Disposition addresses thefrmbNr Title Limitation andSER Condition LOCA analysis is not performed on cycle-specific basis; therefore, the thermal limits applied in theM+SAR LOCA analysis for the 55 percent CFMELLLA+ statepoint and/or the transition statepoint must be either bounding or consistent with cycle-specific off-rated limits. The COLR andthe SRLR will contain confirmation that the off- Sections 4.3.2 and12.10.b rated limits assumed in the ECCS-LOCA analyses Comply 4.3.3bound the cycle-specific off-rated limits calculated for the MELLLA+ operation. Every future cyclereload shall confirm that the cycle-specific off-rated thermal limits applied at the 55 percent CF and/orthe transition statepoints are consistent with thoseassumed in the plant-specific ECCS-LOCA analyses.

12. 1 Ox Off-rated limits will not be applied to the minimum N/A (2)CF statepoint.

If credit is taken for these off-rated limits, the plant12.0 O.d will be required to apply these limits during core Comply Section 4.3.21 monitoring. B-12 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Limitation Section of NMP2Cnd Limitation and M+SAR whichnumber Condition Limitation and Condition Description Disposition addresses thefrmbNr Title Limitation andSER Condition For MELLLA+ applications, the small and largebreak ECCS-LOCA analyses will include top-ECCS-LOCA peaked and mid-peaked power shape in establishing 12.11 Axial Power the MAPLHGR and determining the PCT. This Comply Sections 4.3.2 andDistribution limitation is applicable to both the licensing bases 4.3.3Evaluation PCT and the upper bound PCT. The plant-specific applications will report the limiting small and largebreak licensing basis and upper bound PCTs.12. 12.a Both the nominal and Appendix K PCTs should be Comply Section 4.3.3reported for all of the calculated statepoints, andThe plant-variable and uncertainties currently Reporting applied will be used, unless the NRC staff12.12.b specifically approves a different plant variable Comply Section 4.3.3uncertainty method for application to the non-rated statepoints. Small break LOCA analysis will be performed atthe MELLLA+ minimum CF and the transition Small Break statepoints for those plants that: (1) are small break12.13 LOCA LOCA limited based on small break LOCA analysis Comply Section 4.3.3performed at the rated EPU conditions; or (2) havemargins of less than or equal to [[ ]] relativeto the Appendix K or the licensing basis PCT.B-13 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Limitation Section of NMP2Cnd Limitation and M+SAR whichnumber Condition Limitation and Condition Description Disposition addresses therTitle Limitation andfrom NRC TitleSER Condition The scope of small break LOCA analysis forMELLLA+ operation relies upon the EPU smallBreak break LOCA analysis results. Therefore, the NRC12.14 Spectrum staff concludes that for plants that will implement Comply Section 4.3.1MELLLA+, sufficient small break sizes should beanalyzed at the rated EPU power level to ensurethat the peak PCT break size is identified. Plant-specific MELLLA+ applications shallidentify where in the MELLLA+ upper boundarythe bypass voiding greater than 5 percent will occurabove the D-level. The licensee shall provide in theplant-specific submittal the operator actions andBypass Voiding procedures that will mitigate the effect of the12.15 Above the D- bypass voiding on the TIPs and the core simulator Comply Section 5.1.5Abve used to monitor the fuel performance. Theplant-specific submittal shall also providediscussion on what effect the bypass voiding greaterthan 5 percent will have on the NMS as defined inSection 5.1.1.5. The NRC staff will evaluate onplant-specific bases acceptability of bypass voidingabove D level.Plants operating at the MELLLA+ operating domain shall perform RWE analyses to confirm the12.16 RWE adequacy of the generic RBM setpoints. The Comply Section 9.1.1M+SAR shall provide a discussion of the analyses_performed and the results.B-14 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Limitation Section of NMP2Cnd Limitation and M+SAR whichnumber Condition Limitation and Condition Description Disposition addresses therTitle Limitation andfrom NRC TitleSER Condition As specified in LTR NEDC-33006P, at least twoplant-specific ATWS calculations must beperformed: MSIVC and PRFO. In addition, if RHRcapability is affected by LOOP, then a thirdplant-specific ATWS calculation must beperformed that includes the reduced RHRcapability. To evaluate the effect of reduced RHRcapacity during LOOP, the plant-specific ATWS12.17 ATWS LOOP calculation must be performed for a sufficiently Comply Section 9.3.1.1large period of time after HSBW injection iscomplete to guarantee that the suppression pooltemperature is cooling, indicating that the RHRcapacity is greater than the decay heat generation. The plant-specific application should includeevaluation of the safety system performance duringthe long-term cooling phase, in terms of available NPSH.For plants that do not achieve hot shutdown prior toreaching the HCTL based on the licensing ODYNATWS code calculation, plant-specific MELLLA+12.18.a TRACG implementations must perform best-estimate TRACG calculations on a plant-specific basis. The Comply Section 9.3.1.2Analysis TRACG analysis will account for all plantparameters, including water-level control strategyand all plant-specific EOP actions.B-15 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Limitation Section of NMP2andCnd Limitation and M+SAR whichnumber Condition Limitation and Condition Description Disposition addresses thefrmbNr Title Limitation andSER Condition The TRACG calculation is not required if the plantincreases the boron- 10 concentration/enrichment so12.18.b that the integrated heat load to containment Comply Sections 9.3.1.1 andcalculated by the licensing ODYN calculation does 9.3.1.2not change with respect to a reference OLTP/75 percent flow ODYN calculation. PCT for both phases of the transient (initial12.18.c overpressure and emergency depressurization) must Comply Section 9.3.1.2be evaluated on a plant-specific basis with theTRACG ATWS calculation. B-16 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Limitation Section of NMP2andCondition Limitation and M+SAR whichNumber Condition Limitation and Condition Description Disposition addresses themTitle Limitation andfrom NRC TitleioSER Condition In general, the plant-specific application will ensurethat operation in the MELLLA+ domain isconsistent with the assumptions used in the ATWSanalysis, including EOOS (e.g., FWHOOS, SLO,SRVs, SLS pumps, and RHR pumps, etc.). Ifassumptions are not satisfied, operation inMELLLA+ is not allowed. The SRLR will specifythe prohibited flexibility options for plant-specific MELLLA+ operation, where applicable. For keyinput parameters, systems and engineering safety12.18.d features that are important to simulating the ATWS Comply Section 9.3.1.1analysis and are specified in the TS (e.g., SLSparameters, ATWS RPT, etc.), the calculation assumptions must be consistent with the allowed TSvalues and the allowed plant configuration. If theanalyses deviate from the allowed TS configuration for long-term equipment out- of-service (i.e., beyond the TS LCO), the plant-specific application will specify and justify the deviation. Inaddition, the licensee must ensure that alloperability requirements are met (e.g., NPSH) byequipment assumed operable in the calculations. B-17 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Limitation Section of NMP2andCnd Limitation and M+SAR whichnumber Condition Limitation and Condition Description Disposition addresses thefrmbNr Title Limitation andfrom NRC Condition SERNominal input parameters can be used in theATWS analyses provided the uncertainty treatment and selection of the values of these inputparameters are consistent with the input methodsused in the original GE ATWS analyses in12.18.e NEDE-24222. Treatment of key input parameters Comply Section 9.3.1in terms of uncertainties applied or plant-specific TS value used can differ from the originalNEDE-24222

approach, provided the manner inwhich it is used yields more conservative ATWSresults.The plant-specific application will include12.18.f tabulation and discussion of the key input Comply Section 9.3.1parameters and the associated uncertainty treatment.

B-18 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Limitation Section of NMP2and Limitation and M+SAR whichCondition Lmtto nnumber Condition Limitation and Condition Description Disposition addresses thefrmbNr Title Limitation andfrom NRC Condition SERUntil such time that NRC approves a genericsolution for ATWS instability calculations forMELLLA+ operation, each plant-specific MELLLA+ application must provide ATWSinstability analysis that satisfies the ATWSacceptance criteria listed in SRP Section 15.8. Theplant-specific ATWS instability calculation must:Plant-Specific (1) be based on the peak-reactivity exposure12.19 ATWS conditions, (2) model the plant-specific Comply Section 9.3.3Instability configuration important to ATWS instability response including mixed core, if applicable, and(3) use the regional-mode nodalization scheme. Inorder to improve the fidelity of the analyses, theplant-specific calculations should be based on latestNRC-approved neutronic and thermal-hydraulic codes such as TGBLA06/PANAC 11 andTRACG04.B-19 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Limitation Section of NMP2andCnd Limitation and M+SAR whichnumber Condition Limitation and Condition Description Disposition addresses therTitle Limitation andfrom NRC Condition SEROnce the generic solution is approved, the plant-specific applications must provide confirmation thatthe generic instability analyses are relevant andapplicable to their plant. Applicability confirmation includes review of any differences in plant designor operation that will result in significantly lowerstability margins during ATWS such as:12.20 Generic ATWS

  • turbine bypass capacity, N/A (3)Instability 0 fraction of steam-driven feedwater pumps,9 any changes in plant design or operation thatwill significantly increase core inlet subcooling during ATWS events,* significant differences in radial and axialpower distributions, o hot-channel power-to-flow ratio,0 fuel design changes beyond GE14.B-20 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION

-CLASS I (PUBLIC)Limitation Section of NMP2andCnd Limitation and M+SAR whichnumber Condition Limitation and Condition Description Disposition addresses thefrmbNr Title Limitation andfrom NRC Condition SERLicensees that submit a MELLLA+ application should address the plant-specific risk effectsassociated with MELLLA+ implementation, consistent with approved guidance documents (e.g., NEDC-32424P-A, NEDC-32523P-A, andIndividual Plant NEDC-33004P-A) and the Matrix 13 of RS-00112.21 Evaluation and re-address the plant-specific risk effects Comply Section 10.5consistent with the approved guidance documents that were used in their approved EPU application and Matrix 13 ofRS-001. If an EPU andMELLLA+ application come to the NRC inparallel, the expectation is that the EPU submittal will have incorporated the MELLLA+ effects.The applicant is to provide a plant-specific IASCCevaluation when implementing MELLLA+, whichincludes the components that will exceed theIASCC threshold of 5xl 020 n/cm2 (E> 1MeV), theeffect of failure of these components on the12.22 IASCC integrity of the reactor internals and core support Comply Section 10.7.1structures under licensing design bases conditions, and the inspections that will be performed oncomponents that exceed the IASCC threshold toensure timely identification of IASCC, should itoccur.Limitations Section 9.3.1.112.23.1 from the See limitation 12.18.d. ComplyATWS RAI (4)B-21 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Limitation Section of NM.P2andCnd Limitation and M+SAR whichnumber Condition Limitation and Condition Description Disposition addresses therTitle Limitation andfrom NRC Condition SEREvaluations The plant-specific ODYN and TRACG key12.23.2 calculation parameters must be provided to the staff Comply Sections 1.1.3 andso they can verify that all plant-specific automatic 9.3.1settings are modeled properly. The ATWS peak pressure response would bedependent upon SRVs upper tolerances assumed inthe calculations. For each individual SRV, thetolerances used in the analysis must be consistent with or bound the plant-specific SRV performance. The SRV tolerance test data would be statistically treated using the NRC's historical 95/95 approach12.23.3 or any new NRC-approved statistical treatment Comply Section 9.3.1.1method. In the event that current EPU experience base shows propensity for valve drift higher thanpre-EPU experience base, the plant-specific transient and ATWS analyses would be based onthe higher tolerances or justify the reason why thepropensity for the higher drift is not applicable theplant's SRVs.EPG/SAG parameters must be reviewed forapplicability to MELLLA+ operation in a plant-12.23.4 specific basis. The plant-specific MELLLA+ Sections 9.3.1.1 andapplication will include a section that discusses the Comply 10.9.1plant-specific EOPs and confirms that the ATWScalculation is consistent with the operator actions.B-22 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Limitation Section of NMP2andCnd Limitation and M+SAR whichnumber Condition Limitation and Condition Description Disposition addresses thefrmbNr Title Limitation andSER Condition The conclusions of this LTR and associated SE arelimited to reactors operating with a power densitylower than 52.5 MW/MLBM/hr for operation at the Sections 1.2.3 and12.23.5 minimum allowable CF at 120 percent OLTP. Comply 9.3.3Verification that reactor operation will bemaintained below this analysis limit must beperformed for all plant-specific applications. For MELLLA+ applications involving GE fueltypes beyond GE 14 or other vendor fuels, bounding Section 2.012.23.6 ATWS Instability analysis will be provided to the N/Astaff. Note: this limitation does not apply to (1)special test assemblies. Section 2.012.23.7 See limitation 12.23.6. N/A(1)(5)The plant-specific ATWS calculations must account12.23.8 for all plant- and fuel-design-specific

features, such Comply Section 9.3.1as the debris filters.B-23 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION

-CLASS I (PUBLIC)Limitation Section of NMP2Limitation and M+SAR whichCondition Condition Limitation and Condition Description Disposition addresses theNumberfrmbNr Title Limitation andfrom NRC Condition SERPlant-specific applications must review the safetysystem specifications to ensure that all of theassumptions used for the ATWS SE indeed apply totheir plant-specific conditions. The NRC staffreview will give special attention to crucial safety12.23.9 systems like HPCI, and physical limitations likeNPSH and maximum vessel pressure that RCIC and Comply Section 4.2.6HPCI can inject. The plant-specific application willinclude a discussion on the licensing bases of theplant in terms of NPSH and system performance. Itwill also include NPSH and system performance evaluation for the duration of the event.Plant-specific applications must ensure that anincrease in containment pressure resulting from12.23.10 ATWS events with EPU/MELLLA+ operation does Comply Section 9.3.1.1not affect adversely the operation of safety-grade equipment. The plant-specific applications must justify the useof plant-specific suppression pool temperature 12.23.11 limits for the ODYN and TRACG calculations that Comply Section 9.3.1.1are higher than the HCTL limit for emergency _depressurization. B-24 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Section of NMP2Limitation and M+SAR whichCondition Limitation and Condition Description Disposition addresses theTitle Limitation andCondition For EPU/MELLLA+ plant-specific applications that use TRACG or any code that has the capability Comply Sections 2.6.2 andto model in-channel water rod flow, the supporting 9.3.3analysis will use the actual flow configuration. Limitations The EPU/MELLLA+ application would provide thefrom Fuel exit void fraction of the high-powered bundles inDependent the comparison between the EPU/MELLLA+ and Comply Section 2.1.2Analyses RAI the pre-MELLLA+ conditions. Evaluations Section 2.2.1See limitation 12.6. Comply(6)See limitation 12.18.d. Comply (7)B-25 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Appendix B (Continued) Disposition of additional limitations and conditions related to the final SE forNEDC-33006P, "Maximum Extended Load Line Limit Analysis Plus"Notes:1. NMP2 uses GE14 fuel, therefore, this limitation and condition is not applicable to the NMP2M+SAR.2. Because NMP2 takes credit for off-rated condition at the minimum CF statepoint, theM+LTR requires implementation of Limitation and Condition 12.10.d. Therefore, Limitation and Condition 12.1 O.c is not applicable.

3. This requirement relates to implementation of a generic ATWS Instability
Solution, which isnot yet approved by the NRC. NMP2 MELLLA+ is based on a plant-specific ATWSinstability analysis.
4. This is a repeat of Limitation and Condition 12.18.d.5. This is a repeat of Limitation and Condition 12.23.6.6. This is a repeat of Limitation and Condition 12.6.7. This is a repeat of Limitation and Condition 12.18.d.B-26 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION

-CLASS I (PUBLIC)Appendix CDisposition of additional limitations and conditions related to the draft SE for NEDC-33075P, Revision 7, "General Electric Boiling Water Reactor Detect and Suppress Solution -Confirmation Density"There are four limitations and conditions listed in Section 5 of the DSS-CD LTR SER. The tablebelow lists each of the four limitations and conditions. The table also shows that NMP2complies with all four of the limitations and conditions. The table identifies which section ofthis M+SAR discusses compliance with each limitation and condition. C-I NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Appendix C (continued) Disposition of additional limitations and conditions related to the draft SE for NEDC-33075P, Revision 7, "General Electric BoilingWater Reactor Detect and Suppress Solution -Confirmation Density"Limitation and Section of NMP2 M+SARCondition Limitation and Condition Description Disposition which addresses the Limitation Numberfrom NRC and Condition SERThe NRC staff previously reviewed and approvedthe implementation of DSS-CD using the approvedGEH Option III hardware and software. TheDSS-CD solution is not approved for use withnon-GEH hardware. The hardware components Section 2.45.1 required to implement DSS-CD are expected to be Complythose currently used for the approved Option III. If (1)the DSS-CD hardware implementation deviatesfrom the approved Option III solution, a hardwarereview by the NRC staff will be required. Implementations on other Option III platforms willrequire plant-specific reviews.The CDA setpoint calculation formula and theadjustable parameters values are defined inNEDC-33075P, Revision 7 (Reference 2).Deviation from the stated values or calculation formulas is not allowed without NRC review. To Scin245.2 this end, the subject TR, when approved and Complyimplemented by a licensed nuclear power plant, (2)must be referenced in the plant TSs, so that thesevalues become controlled and part of the licensing bases.C-2 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Limitation andCondition Section of NMP2 M+SARNditio Limitation and Condition Description Disposition which addresses the Limitation from NRC and Condition SERThe NRC staff previously concluded that theplant-specific settings for eight of the FIXEDparameters and three of the ADJUSTABLE 53 parameters, as stated in section 3.6.3 of the NRC Comply (3)staff's SE for NEDC-33075P, Revision 5(Reference 58), are licensing basis values. Theprocess by which these values will be controlled must be addressed by licensees. If plants other than Brunswick Steam Electric Plant,Units 1 and 2, use the DSS-CD trip function, those5.4 plant licensees must ensure the DSS-CD tripfunction is applicable in their plant licensing bases, Comply (4)including the optional BSP trip function, if it is tobe installed. C-3 NEDO-33576 REVISION 0NON-PROPRIETARY INFORMATION -CLASS I (PUBLIC)Appendix C (continued) Disposition of additional limitations and conditions related to the draft SE for NEDC-33075P, Revision 7, "General Electric Boiling Water Reactor Detect and Suppress Solution -Confirmation Density"Notes:1. The DSS-CD solution is implemented on GEH hardware that is currently installed andapproved by the NRC for the Option III solution.

2. The subject TR, or GESTAR II, is referenced in the NMP2 TSs.3. The values of the FIXED and ADJUSTABLE parameters are established by GEH and will bedocumented in a DSS-CD Settings Report.4. Verification and validation (V&V) of the DSS-CD trip function code was performed fortransportability considerations.

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